Strategy Effective from April 2011
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Strategy Effective from April 2011
Strategy Effective from April 2011 Strategy presented to Parliament pursuant to Schedule 2 of the Energy Act 2004. Strategy presented to Scottish Parliament pursuant to Schedule 2 of the Energy Act 2004.
Some images supplied courtesy of site licence companies. Every effort is taken to ensure the accuracy of material or images produced or used by the NDA. However, the NDA cannot guarantee that the images shown will always be current, accurate or complete and does not warrant or endorse the accuracy or completeness of the images. Copyright © Nuclear Decommissioning Authority 2011 ISBN 978-1-905985-26-5
Contents
Preface 5 4.0 Critical Enablers 54
1.0 Introduction 6 4.1 Health, Safety, Security, Safeguards,
1.1 Background 7 Environment and Quality 56
1.2 Our Approach to Strategy 8 4.2 Research & Development 57
1.3 Lessons from 2006 10 4.3 People (incorporating Skills and Capability) 58
1.4 Public Consultation Response 10 4.4 Asset Management 59
2.0 Strategy Overview 12 4.5 Contracting and Incentivisation 60
3.0 Our Strategy 16 4.6 Competition 61
3.1 Site Restoration 16 4.7 Supply Chain Development 62
3.1.1 Decommissioning 18 4.8 Information and Knowledge Management 63
3.1.2 Land Quality Management 20 4.9 Socio-Economics 64
3.1.3 Site End States 22 4.10 Public and Stakeholder Engagement
and Communications 65
3.2 Spent Fuels 24 4.11 Transport and Logistics 66
3.2.1 Spent Magnox Fuel 26 4.12 Funding 67
3.2.2 Spent Oxide Fuel 28 4.13 International Relations 68
3.2.3 Spent Exotic Fuels 30 5.0 Non NDA Liabilities 69
Appendices 70
3.3 Nuclear Materials 32 A Introduction to the Strategy
3.3.1 Plutonium 34 Management System (SMS) 70
3.3.2 Uranics 36 B Summary of the Strategic
Environmental Assessment (SEA) 72
3.4 Integrated Waste Management 38 C Information on our Designated Sites and
3.4.1 Higher Activity Waste 41 Installations 78
3.4.2 Lower Activity Waste 44 D Summary of Expected Expenditure
3.4.3 Non-Radioactive and Hazardous Waste 47 and Income 90
Glossary 91
3.5 Business Optimisation 48 References 94
3.5.1 Revenue Optimisation 50 Abbreviations 95
3.5.2 Land and Property Management 52
Please note throughout the document the following styles
are used:
Glossary terms are italicised -
e.g. ‘Care and Maintenance’
References are italicised -
e.g. ‘Energy Act (2004) (ref 2)
NDA Strategy - Published March 2011
Published by the Nuclear Decommissioning Authority 2011
Copyright © Nuclear Decommissioning Authority 2011
ISBN 978-1-905985-26-5
Contents 03
Dounreay’s changing landscapes - Preparations underway to place an underwater explosive charge
during the construction of the Seawater Pumphouse at the Dounreay Fast Reactor (DFR) in the 1950s.
Redundant facilities being demolished at Dounreay in 2007.
04 Preface
Preface
The Energy Act 2004 requires the Nuclear Decommissioning
Authority (NDA) to review and publish its Strategy at least
every five years.
This document presents the outcome of our review of knowledge relating to spent fuel management
our !rst Strategy (ref 1) published in 2006. This revised and reprocessing, waste management and
Strategy sets out our strategic direction and describes decommissioning lies within the NDA estate and it is
our long-term objectives. It covers the duration of our important this expertise is made available to the UK’s
mission, while summarising the current position at the broader nuclear programme. Where appropriate this
time of publication. is re"ected in our Strategy.
This Strategy has been approved by the Secretary of We deliver our mission through others, primarily Site
State jointly with the Scottish Ministers as required by Licence Companies (SLCs) which are licensed to
the Energy Act (2004) (ref 2). operate our nuclear sites. Between them the SLCs
employ a workforce of around 18,000 and deliver
The NDA’s Strategy is supplemented by our annual
agreed programmes of work against schedule and site
Business Plan, which sets out near term objectives
funding limits. Through competition we let contracts
and plans for delivering our priorities over the following
to winning bidders to contribute the bene!ts of their
three year period. Performance against the activities
proven track record in the management of nuclear
included in our Business Plan is reported in our Annual
decommissioning to improve the performance and
Report and Accounts.
delivery of the SLCs. The winning bidders own the
The NDA’s sponsoring department is the Department SLCs for the period of the contract, and as Parent
of Energy and Climate Change (DECC) and, for Body Organisations (PBOs) provide additional
matters affecting Scotland, we have additional resource and management expertise.
obligations to the Scottish Ministers. We operate
In order that we can continue to deliver our Strategy
under a Management Statement and Financial
within the funds available we must continue to maximise
Memorandum, which sets out the relationship
our income, achieve greater ef!ciencies and prioritise
between DECC, Scottish Government and the
our effort and resources to best effect. The NDA will focus
NDA. Our budget is set by DECC and comes from a
its resources on core tasks and deliver everything else
combination of Government funding and income from
through others, particularly our SLCs and their PBOs.
our commercial activities.
We are looking to consolidate our position as a
The NDA is a Non-Departmental Public Body created
world class contract management organisation. We
under the Energy Act (2004) (ref 2). Our core objective
will select, lead, manage and hold to account those
is to ensure that the historic civil public sector nuclear
who deliver our mission on our behalf, and reward
legacy sites are decommissioned safely, securely, cost
our contractors for delivering excellence. We will set
effectively and in ways that protect the environment.
clear strategies, articulate stretching performance
As part of this, we are required to operate existing
targets and introduce appropriate incentives to drive
commercial activities and meet current contracts,
improved delivery from the PBOs and SLCs. We
using revenues generated to offset spend on
will continually review the way we operate and the
decommissioning. In addition, we are required to
capabilities we need to perform these functions.
scrutinise the site decommissioning plans of EDF
Energy for their existing nuclear "eet; and, since We will continue to work closely with Government
October 2006, we have been the UK body responsible and in partnership with stakeholders to maintain their
for implementing geological disposal of higher activity con!dence, inform policy development and support
radioactive waste. We are also responsible for the maintenance of nuclear industry infrastructure
delivering the Low Level Radioactive Waste Strategy such as developing skills and ensuring suf!cient
(ref 22) for the whole of the UK’s nuclear industry, Research & Development (R&D) is undertaken
which we published in 2010. to underpin our decommissioning and waste
management plans. We will continue to support the
Our responsibilities under the Energy Act (2004)
sustainable economic development of communities
(ref 2) are unchanged and our review has con!rmed
affected by our activities.
that much of our original Strategy remains relevant.
However, the background against which we operate The NDA will continue to deliver a step change
has changed signi!cantly since the NDA was improvement to programme, project and operational
established. UK Government policy on nuclear energy execution, and focus delivery on tangible, medium-
has changed and a new reactor programme is now term achievements in decommissioning and clean-
envisaged in England and Wales. This does not up. This Strategy supports our aim by making clear
change our mission, but it does mean we need to our strategic direction in order that the SLCs, PBOs
consider the impact of this new reactor programme and other stakeholders can understand and drive
where potential synergies exist, such as skills and towards common outcomes, thereby delivering our
nuclear industry infrastructure. Much of the UK’s mission more effectively.
Preface 05
Our top decommissioning and clean-up priority continues to be dealing with the higher hazard facilities
at Sella!eld and Dounreay – one facility in particular being the Magnox Storage Pond at Sella!eld.
06 1.0 Introduction
1.0 Introduction
1.1 Background
The UK’s civil nuclear legacy is a major public liability,
and represents the largest, most important environmental
restoration programme in Europe.
Our mission is to deliver safe, sustainable and publicly requirement. The Scottish Government policy is for the
acceptable solutions to this challenge, driving long-term management of higher activity radioactive
substantial change to improve delivery using competition waste in near surface facilities, as de!ned in its January
for contracts to bring in world class expertise to 2011 Policy Statement (ref 26).
enhance innovation, improve clean-up and deliver
Whilst decommissioning and clean-up is the NDA’s
value for money.
core objective, in our !rst six years only a quarter of
The nature and scale of the task to decommission the budget has been spent directly on site restoration.
the legacy facilities inherited by the NDA was The balance of expenditure is spent on maintaining
poorly characterised and highly uncertain. An early the sites in a safe and secure state as well as running
objective was for the NDA to form a comprehensive the operations associated with fuel and waste
understanding of the work to be done and the management. It is a clear objective of the NDA to
associated costs. Although uncertainties still remain, increase the proportion of site restoration expenditure.
the total discounted costs of completing the NDA’s
In our !rst six years, we have made signi!cant progress
mission were estimated in 2009/10 to be £45.1 billion1.
on a number of fronts. We have:
The high cost of dealing with the historic civil public
— developed a detailed understanding of the legacy,
nuclear liability re"ects the emphasis at the time the
introducing industry-wide procedures across our
facilities were built on operations and the lack of
sites to plan on a consistent basis and completed
awareness or foresight of the importance and need to
the re-structuring of our estate to facilitate the
plan for eventual decommissioning.
programme of competitions
In the NDA, the UK now has a single body responsible
— progressively prioritised funds towards highest
for an ever improving understanding of the civil public
hazards
nuclear liabilities, and for developing and implementing
an estate-wide strategy and plans to deal with them. — delivered value for money by driving ef!ciency and
performance across our estate
Our sites range from Sella!eld, a complex site
providing fuel reprocessing, fuel fabrication and — successfully completed competitions for
storage of nuclear materials and radioactive wastes the management of the Low Level Waste facility
across two square miles, to smaller sites containing near Drigg; and for Sella!eld – one of the largest
nuclear research facilities, where decommissioning is and most complex procurements in Europe -
well underway. Some of our facilities continue to form bringing international capability to the UK with the
an essential part of the nation’s nuclear infrastructure expectation of signi!cant improvements in
which means they must continue to be operated safely operational ef!ciency, project management and
and effectively until they have ful!lled their purpose. cost control
Our mission is a long-term one and some sites will — made signi!cant headway in realising value from our
not reach their planned end state for decades; some commercial operations and surplus assets
wastes will remain hazardous for thousands of years.
This is immensely technical and challenging. Much — invested in skills to build the future capability of the
of the plant and assets are in a severely deteriorated UK’s nuclear workforce
condition due to an historic lack of investment, not — made steady progress on decommissioning
only in decommissioning but also in the maintenance and the operations associated with fuel and waste
of the estate. As such, there is an imperative to make management despite challenges associated with
progress whilst various plants and facilities remain plant reliability.
operational. The alternative brings a signi!cant risk
of additional expense as well as compromising the These and other achievements have provided a secure
environment and safety. platform for our next phase of delivery.
Plans for decommissioning the sites rely upon the
availability of a !nal disposal solution for waste. For
Low Level Waste, the NDA’s primary task is to reduce
the amount of waste for disposal in order to avoid
unnecessary costs. For Higher Activity Wastes, the UK
Government’s chosen solution is for deep geological
disposal and the availability of a repository is the key
1
The discounted cost is detailed in our published Annual Report and Accounts 2009/2010 (ref 4).
1.0 Introduction 07
1.2 Our Approach to Strategy
In order to bring a clear focus to our mission we have identi!ed six strategic themes under which we group all our
activities. The six themes are:
See p16 Site Restoration de!nes our approach to decommissioning redundant facilities and how we manage
contamination in ground and groundwater. Restoration will drive our sites through a series of Interim States to a
Site End State, at which point the NDA is able to release the site for other uses.
See p24 Spent Fuels de!nes our approach to managing the diverse range of spent nuclear fuels for which we have
responsibility, including Magnox, oxide and exotic spent fuels.
See p32 Nuclear Materials de!nes our approach to dealing with the inventory of uranics and plutonium currently stored
on some of our sites.
See p38 Integrated Waste Management considers how we manage all forms of waste arising from operating and
decommissioning our sites, including waste retrieved from legacy facilities. It also ties in the wider work of our
Radioactive Waste Management Directorate on implementing geological disposal.
See p48 Business Optimisation looks at how we maximise our commercial income, using our assets and capabilities to
reduce the net cost of decommissioning and clean-up to the taxpayer.
See p54 Critical Enablers support the overall delivery of our mission and, in some cases, re"ect the supplementary duties
assigned to the NDA by the Energy Act (2004) (ref 2). In most cases these are not matters in which we have the
lead role, but where we need to take a view and ensure that appropriate action is being taken. Critical Enablers
apply across the other strategic themes and enable their delivery.
Throughout this document, colour coding is used to indicate the strategic themes, as above.
Time
Figure 1 - This illustrates the interaction of the six strategic themes showing Site Restoration as the driving
theme supported by Integrated Waste Management; the need to manage Spent Fuels and Nuclear Materials
as an early part of Site Restoration; Business Optimisation raising revenues where appropriate; and with the
entire mission underpinned by the Critical Enablers. Time passes from left to right.
08 1.0 IntroductionOur strategic themes are further divided into individual We call this combination of factors our Value
strategies which we develop and maintain to ef!ciently Framework, which helps us balance our top priority of
deliver our mission under the Energy Act (2004) (ref 2). risk and hazard reduction alongside socio-political and
This Strategy is structured to re"ect the strategic affordability considerations.
themes and organising our work in this way has
already provided clarity and a consistent basis for Strategic decisions are made in the light of an
communicating with contractors and stakeholders. informed assessment of the relevant factors and their
interplay, through the Value Framework, with clarity on
Site Restoration is our driving strategic theme and all where accountability for making the decision lies and
other strategies support or enable its delivery. We can with a rationale for the outcome being associated with
only restore our sites if we manage spent fuels and each decision.
nuclear materials ef!ciently, establish effective waste
management solutions and secure suf!cient income to We engage or consult with relevant stakeholders at
continue making progress. the appropriate stage in the development of strategy,
to ensure their views are considered.
There is a great deal of interdependence between
the strategic themes. There is, therefore, limited By considering the factors in our Value Framework, we
discretion to stop activities under a particular theme incorporate the requirements of Strategic Environmental
without wider implications. This includes impacting Assessment (SEA) (ref 3) into the heart of our strategy
critical national infrastructure that serves the wider development and decision making. SEA ensures our
nuclear industry such as electricity generation, fuel decisions are informed by an assessment of
manufacture, reprocessing and waste treatment, environmental bene!ts and drawbacks of alternative
storage and disposal services. options, and where relevant these are set out in this
Strategy. An overarching SEA has been carried out for
Our published Strategy covers the duration of our this Strategy, summarised in Appendix B. In addition,
mission and summarises the current position and as part of strategy development, individual strategies
maturity at the time of publication. Strategy review are subjected to an SEA as appropriate.
and development is, however, an ongoing process for
the NDA and options for delivering the strategy are To secure implementation, our strategic requirements
continually evolving. are translated into action by issuing Site Strategic
Specifications to our SLCs. These speci!cations detail
To manage the complex interactions between the what our Strategy means for a particular site, which
different parts of our Strategy we have a Strategy then become embedded in its Lifetime Plan (ref 5).
Management System (SMS) which enables us to: The NDA subsequently monitors and measures the
SLC’s delivery performance against the agreed
— develop strategy in a controlled fashion through
Lifetime Plan (ref 5).
distinct stages allowing us to engage effectively
with Government, nuclear regulators, SLCs For each strategy in this document we have
and other stakeholders on its development and considered four questions under the following
possible changes in strategic direction headings:
— ensure the strategy is robust and coherent at all — Objective – What is the objective of the strategy?
times, recognising the numerous interdependencies
— Our Strategy – What is our current strategy, and
— effectively respond to internal and external events any associated risks and opportunities?
that impact our strategy
— Development – What strategy development do
— ensure compliance with the regulatory framework we plan to undertake in the future?
— transparently underpin the decisions we make — Delivery – What have we delivered so far and how
on preferred strategic options. do we plan to implement our strategy?
The SMS is based on HMG Treasury guidance, In each Development section we make clear if an
using a business case approach to build up the individual strategy is undergoing development, with
underpinning rationale for a strategic decision. In input from relevant stakeholders, or is mature and
selecting a preferred strategy we consider the options being implemented.
against a wide range of factors, shown in Figure 2 below.
Further information on how we develop strategy is
provided in Appendix A.
Safety Impact
Hazard Reduction
Environmental Impact
Cost (Long & Short-Term)
Income
Economic & Social Effects
and
Other Relevant Factors on a case speci!c basis
Figure 2 - NDA Value Framework
1.0 Introduction 091.3 Lessons from 2006
Following the publication of our !rst Strategy (ref 1) in statements are aspirational and indicate the extent to
2006, we examined the way we approach the which we can deliver against them.
development of strategy, particularly our engagement
We have also learned that we need to make clear the
with stakeholders. We identi!ed a clear need to
maturity of our individual strategies, stating where
pre-engage and work with key stakeholders,
preferred options have been approved and adopted or
particularly nuclear regulators, during the development
further development or underpinning is still required to
of our strategy and before the consultation, to ensure
make a decision on strategic direction. This helps our
it contained ‘no surprises’.
stakeholders engage with us and contribute effectively
We recognised that we should not include tactical and to the development of strategy.
operational details in our Strategy. They are more
We have re"ected on these lessons, and others, to
appropriate to our Business Plans. Our !rst Strategy
help us prepare this Strategy.
contained a number of detailed operational targets
which were replaced in light of experience by
alternative ways of achieving our objectives. It also
contained aspirational commitments and targets
which, for one reason or another, we were unable to
deliver. In future we need to make clear where
1.4 Public Consultation Response
We consulted on our Draft Strategy (ref 27) and the In summary, the responses we received were broadly
supporting Environmental and Sustainability Report supportive of our proposed Strategy and considered
(ref 3) between 1 September and 24 November 2010. the Strategic Environmental Assessment (SEA) (ref 3)
During the consultation period we issued around methodology to be sound. Many stakeholders
2,600 copies in total and delivered numerous welcomed the clarity provided, particularly our
presentations around the UK to interested parties and approach using strategic themes supported by critical
statutory consultees. These included Site Stakeholder enablers, which helped them to understand our scope
Groups, Trade Unions, Local Authority representatives and the challenges we face. Additional detail has been
from England, Wales and Scotland, site staff and provided in a number of areas for clarity, as suggested
management teams, supply chain forums and the by some respondents.
NDA National Stakeholder Group.
The consultation on our supporting Environmental and
In response we received 74 sets of comments on the Sustainability Report (ref 3) resulted in 12 stakeholder
Draft Strategy (ref 27) from a wide range of stakeholders. responses, none of which affected the original
All comments received were considered and assessed strategic environmental assessment or the proposed
to determine their in"uence and impact on the Strategy. Strategy. In response to feedback, the summary
In response to the consultation, the NDA has provided in Appendix B has been revised to improve
published two documents on the NDA website clarity of the SEA on the Draft Strategy.
www.nda.gov.uk First, a report that summarises
The Post Adoption Statement, which details how the
stakeholder responses to the Draft Strategy, and
SEA has in"uenced this !nal Strategy, can also be
describes how the comments received informed this
found on our website www.nda.gov.uk
!nal Strategy, and second, a spreadsheet that
provides the NDA’s response to each individual
comment received.
10 1.0 IntroductionWorkmen remove pipework from one of the reactors at Berkeley.
1.0 Introduction 11Removal of redundant buildings surrounding the PLUTO reactor, Harwell 2008. 12 2.0 Strategy Overview
2.0 Strategy Overview
At the heart of our Strategy is the priority we apply to
delivering a reduction in risk and hazard across our estate
and to delivering our mission cost-effectively.
Firstly, where risks to people or the environment are This particularly applies to waste management and
intolerable2, making tangible, demonstrable progress decommissioning. Such solutions may challenge
on these national priorities is our priority, particularly historic practices or the current regulatory framework,
Sella!eld’s Legacy Ponds and Silos. Secondly, where but could reduce environmental impact and provide
the risk is tolerable we will pursue hazard and risk greater value for money, so we will continue to
reduction. Finally, where risks are broadly acceptable evaluate their technical and economic viability. We will
and hazards have been reduced, our attention turns ensure that our plans re"ect full lifecycle strategies for
to site restoration in line with our Site Interim and everything we are accountable for.
End State objectives. These priorities will drive the
By adopting more sophisticated and diverse solutions
allocation of resources.
to the challenges we face, stakeholders and the
We recognise that to deliver the reduction in risk and communities neighbouring our sites will reap bene!ts
hazard that is core to our mission, we may need to accept in the medium-term, such as visible and tangible
near term increases in risk. We will work with our SLCs restoration progress, reduced risk pro!les and the
and the Regulators to safely manage this balance. eventual release of land for other uses.
From the secure platform achieved in our !rst six years To deliver our plans within the funds available we must
we will extract value from the industry restructuring continue to maximise our income, achieve greater
we have delivered and ensure effective deployment ef!ciencies, and prioritise our efforts and resources
of our capabilities. We will continue to use the NDA to best effect. We will reinforce our role as a strategic
contracting model of a Site Licence Company authority and deliver through others, ensuring that
(SLC) contracted to the NDA, with ownership and work is placed with those best able to deliver.
management of the SLC competed into the market to
We recognise that openness, transparency, and
bring UK and international best practice to bear on our
effective public and stakeholder engagement and
mission. Re"ecting the maturity of our plans and the
communications are key to building and maintaining
marketplace, we will increasingly use output-based
the support, con!dence and trust of the public and
contracts, specifying the outcomes we seek rather
stakeholders necessary to implement our Strategy. As
than the work to be performed and rewarding cost-
our Strategy develops we will continue to engage with
effective delivery. This will include an appropriate and
local communities, local authorities and other relevant
progressive transfer of risk to the private sector.
stakeholders as appropriate, for example, on matters
Early planning of site restoration inevitably focused such as Site End States and de!ning Interim States,
on site by site solutions, supported by only a few options for oxide fuel management, the possible
generic waste and material management techniques. use of centralised and multi-site waste and material
In future, more sophisticated and diverse approaches management solutions and the transportation of
will be needed to improve delivery and secure waste and nuclear materials.
best value. The NDA has a wide range of human
We incorporate the requirements of Strategic
resources and physical assets across its estate and
Environmental Assessment (SEA) (ref 3) into the heart
we will make better use of these in delivering our
of our strategy development and its implementation.
mission. For example, this may include encouraging
The Post Adoption Statement (found on
workforce mobility, or moving materials and waste
www.nda.gov.uk) describes indicators that we
from one site to another where the facilities exist to
will use to monitor signi!cant environmental and
best manage them. We will balance the bene!ts of
sustainability effects during Strategy implementation.
generic techniques and problem speci!c solutions to
ensure that we deliver our mission most effectively.
2
For de!nition of intolerable risk refer to the Glossary p 92.
2.0 Strategy Overview 13Site Restoration
The NDA’s end goal is to restore our designated sites to Where risks have been reduced, there is still work to be
the point where they are released for other uses. In order done. Decisions on further site restoration will balance
to prioritise delivery our site restoration strategy focuses the broad range of factors in our Value Framework.
on reducing risks to people and the environment while
restoring each site as soon as reasonably practicable to Our decisions will consider the full lifecycle impacts on
a condition suitable for its next planned use. people and the environment to ensure that the chosen
strategic option does not compromise the needs of
Due to the unique and varied nature of our facilities future generations. We have agreed Site End States
and land, restoration is considered on a case-speci!c which de!ne our long-term restoration objectives.
basis. We take into account a range of relevant In addition, we will identify Interim States to focus
factors, including the need to re"ect Government delivery on nearer term restoration goals. These will be
policy and secure value for money. measurable, demonstrable and could align to stepped
risk or hazard reduction targets, decommissioning
Our approach is in"uenced by the level of risk to phases, contract delivery milestones or opportunities
people or the environment. to release land for its next planned use.
Where the risks are intolerable we will take urgent We will encourage innovation and, where appropriate,
action to reduce them. resources such as equipment, skills and experience
Where the risk is less signi!cant our approach takes will be shared between sites to improve site restoration
greater account of other factors. However, it is still across our estate.
focused on reducing risk and hazard as far as is
reasonably practicable. We will monitor existing risk Definition of Hazard
levels and act proportionately to ensure that the net Hazard is the potential for harm arising from an intrinsic
level of risk does not increase in the long-term. property or ability of something to cause detriment.
We recognise that to deliver the reduction in risk and
hazard that is core to our mission, we may need to Definition of Risk
accept near term increases in risk. We will work with our
SLCs and the Regulators to safely manage this balance. Risk is the chance that someone, or something that is
valued, will be adversely affected by the hazard.
Spent Fuels
Our strategy is to secure and subsequently implement Where appropriate, we will invest in our spent fuel
the most appropriate management approach for management capability. In particular, we will continue
Magnox and oxide fuels and, where possible, take to invest in developing contingency and alternative
advantage of these approaches to manage exotic options in the event that reprocessing or long-term
fuels. Any remaining fuels will continue to be managed fuel storage management capabilities are not available.
on a case-speci!c basis in a safe and secure manner This will enable us to make fully informed investment
pending subsequent disposition. decisions for optimising spent fuel management as
required in the near future.
The most cost-effective solutions for Magnox and
oxide fuels will include continued and extensive use of If approached by third parties to provide additional
our existing reprocessing and storage facilities. spent fuel management services, we will discuss the
options with UK Government.
We intend to continue using the oxide, Magnox and,
where appropriate, exotic fuels management routes in With UK Government agreement we will, if requested,
an integrated way to optimise utilisation of facilities at supply advice and information to utilities involved in the
Sella!eld and across our estate. UK’s new reactor programme, on a commercial basis.
Nuclear Materials
Our strategy for the management of nuclear materials will consider whether consolidated storage is more
re"ects the current UK Government policy of safe and appropriate for reasons of security and economy and
secure storage. We are developing options which consider other nuclear material owners in developing
consider alternative lifecycle management solutions. our plans.
Some of our nuclear materials have value in today’s We will support UK Government as it determines
market. The rest of the inventory may increase in value in future policy on plutonium and we will subsequently
the future. Our strategy for these materials is therefore deliver appropriate strategies. This includes R&D work
to maximise value and avoid foreclosing any future to technically underpin the options.
options unless there is a hazard management priority.
Our strategy for material owned by third parties is
The nuclear materials inventory is stored safely and to continue its management in accordance with
securely on several sites across the NDA estate. We contractual obligations and UK Government policy.
Integrated Waste Management
Strategic decisions about waste management are — the Waste Hierarchy should be used as a
informed by the following key principles: framework for waste management decision making
and enables an effective balance of priorities
— risk reduction is a priority
including value for money, affordability, technical
— centralised and multi-site approaches should be maturity and the protection of health, safety,
considered where it may be advantageous security and the environment.
— waste should be minimised
14 2.0 Strategy OverviewWe will continue to promote the importance of example local authorities, to build on the feedback
waste characterisation, improved waste information we have received on how this engagement should
See p63 (see Information and Knowledge Management happen and develop a framework for engagement
Strategy) and waste segregation to facilitate waste that provides for useful discussion when considering
management planning and application of the Waste new waste management initiatives.
Hierarchy.
We believe there are opportunities for a more "exible
See p41 Our Higher Activity Waste Strategy is to implement approach in the management of waste that is close
the UK Government’s policy of deep geological to category boundaries. For example, decay storage
disposal and the Scottish Government policy for long- of ILW may make the use of LLW treatment and
term management in near surface facilities. For LLW, disposal routes feasible. We will consider the role that
disposal will be in !t for purpose facilities that re"ect these opportunities can provide.
the nature of the wastes to be managed.
We will encourage innovation and open market
Within this overall framework our priority is to achieve solutions, and sustain R&D matched to the challenges
risk reduction by dealing with waste in ageing storage of waste management both by direct investment and
facilities (for example legacy facilities at Sella!eld) and indirectly through the programmes of our SLCs.
placing it into safer modern storage conditions.
The NDA intends to take a multi-site and UK-wide
Diverse radioactive waste management and view, to include its own sites and the operations of
disposal solutions will be pursued where these offer other waste producers, including EDF Energy* and
bene!ts over previous arrangements. We will also MoD. We recognise that in future the radioactive
investigate opportunities to share waste management waste management landscape will change, particularly
infrastructure across the estate and with other waste as a result of the UK’s new reactor programme. With
producers where we can see bene!t. New waste UK Government agreement we will supply advice and
management approaches will often require different information to utilities involved in the programme. This
transport arrangements and will be a matter of great will ensure both an integrated approach to radioactive
interest to planning authorities and people living close waste management and that our facilities, some of
to the sites involved. We will engage with interested which support both the civil and defence nuclear
parties from an early stage, irrespective of whether industries, can plan effectively for the future.
such developments represent new investments
proposed by us or by other organisations on our
behalf. We will work with key organisations, for
Business Optimisation
To help fund decommissioning and clean-up without — disposing of surplus assets and reducing liabilities
materially impacting on our core mission, or increasing
— working with others to share costs to the bene!t
liabilities, we will develop commercial opportunities to
of the UK taxpayer.
maximise revenue from our existing assets, operations
and people. These opportunities may include: Some of these opportunities may arise from the UK’s
new reactor programme. Successful past examples of
— deploying existing facilities and resources to our
this approach are the sale of land and the transfer of
commercial advantage
Spring!elds Fuels Limited to the private sector.
Critical Enablers
We will continue to develop approaches for the critical — People – We recognise that people with appropriate
enablers required to deliver our strategies effectively. skills and capabilities are essential to the successful
Through engagement with stakeholders we have delivery of our mission over its lifecycle and aim to
established our strategic direction and appropriate ensure that there is a skilled workforce available at
working arrangements. Notably: all times within our organisation, the SLCs and the
supply chain.
— Health, Safety, Security, Safeguards,
Environment & Quality (HSSSEQ) – — Research & Development (R&D) – Our strategy is
Our strategy is to take account of the health, safety, that, where possible, R&D is undertaken by the SLCs
security, safeguard and environmental implications and their supply chain. Where necessary the NDA
of different approaches to ful!lling our mission will maintain a strategic R&D programme, which
during our development and decision processes. focuses on targeted, estate-wide R&D needs, risks
We will select Parent Body Organisations with an and opportunities to inform and develop strategy,
excellent track record in health, safety, security, encourage innovation and support key technical skills.
safeguards and environmental management. We
will ensure that our SLCs have a clear vision for — Socio-Economics – Our strategy is to support the
improving HSSSEQ performance and insist they economic development of communities affected by
have high standards of HSSSEQ performance. We our activities, focusing on employment, education
will monitor SLC performance and outcomes, and and skills, economic and social infrastructure and
work with Regulators, Government and SLCs to diversi!cation.
improve and rationalise legislation and its application, — Public and Stakeholder Engagement and
where changes would offer signi!cant bene!ts in the Communications - We regard openness,
delivery of our mission. We will seek innovative ways transparency and effective public and stakeholder
to share good practice across our estate and learn engagement and communications as key to
lessons from other industries. building and maintaining the support, con!dence
and trust necessary for us to deliver our mission.
* Formerly British Energy
2.0 Strategy Overview 153.1 Site Restoration
Objective:
To restore our designated sites and release them for other uses.
The clean-up team at work in the giant sodium storage tank of the Prototype Fast Reactor (PFR), Dounreay.
16 3.1 Site Restoration3.1 Site Restoration
Site restoration is our primary focus and all other strategic
themes support or enable its delivery.
We can only restore our sites if we secure !nal — legacy plants in excess of 60 years old containing
management solutions for spent fuels and nuclear signi!cant quantities of corroding radioactive
materials and establish effective waste management material which represent our highest risk and
solutions. Site restoration must take account of non- some of our largest hazards
NDA liabilities located on our sites, such as those owned
— infrastructure which has been deteriorating
by the Ministry of Defence (MoD) or EDF Energy.
for several decades
The restoration of our sites presents a number of — land contamination resulting from a variety
major challenges: of past uses, including non-nuclear activities.
Our Strategy
The NDA’s end goal is to restore our designated
sites to the point where they are released for other
INCREASING FLEXIBILITY OVER TIMING OF REMEDIAL ACTIONS
uses. In order to prioritise delivery our site restoration
strategy focuses on reducing risks to people and Intolerable
the environment while restoring each site as soon as — Risk is the overriding
reasonably practicable to a condition suitable for its factor in decision-making
INCREASING RISK TO PEOPLE AND THE ENVIRONMENT
next planned use. — Urgent action is required
Due to the unique and varied nature of our
facilities and land, restoration is considered on a
case-speci!c basis. We take into account a range
of relevant factors, including the need to re"ect
Government policy and secure value for money.
Tolerable
Our approach is in"uenced by the level of risk to
people or the environment, as shown in Figure 3. — Risk and hazard reduction
are key considerations
Where the risks are intolerable we will take urgent — Options appraisal considers
action to reduce them. a broad range of factors
Where the risk is less signi!cant our approach takes
greater account of other factors. However, it is still
focused on reducing risk and hazard as far as is
reasonably practicable. We will monitor existing risk
levels and act proportionately to ensure that the
net level of risk does not increase in the long-term. Broadly Acceptable
We recognise that to deliver the reduction in risk and — Driver is mission completion
hazard that is core to our mission, we may need to — Options appraisal balances
accept near term increases in risk. We will work with a broad range of factors
our SLCs and the Regulators to safely manage this
balance.
Where risks have been reduced, there is still work
to be done. Decisions on further site restoration Figure 3 - Summary of our approach to prioritisation
will balance the broad range of factors in our Value and risk
Framework.
These will be measurable, demonstrable and could
Our decisions will consider the full lifecycle impacts align to stepped risk or hazard reduction targets,
on people and the environment to ensure that the decommissioning phases, contract delivery milestones
chosen strategic option does not compromise the or opportunities to release land for its next planned use.
needs of future generations. We have agreed Site
End States which de!ne our long-term restoration We will encourage innovation and, where appropriate,
objectives. In addition, we will identify Interim States resources such as equipment, skills and experience
to focus delivery on nearer term restoration goals. will be shared between sites to improve site restoration
across our estate.
The strategies underpinning Site Restoration are:
Decommissioning: To deliver Site End States as soon as reasonably practicable with a progressive
reduction of risk and hazard.
Land Quality Management: To ensure that land quality is managed to protect people and the environment.
Site End States: To de!ne credible objectives for the restoration of each site (or part of a site).
3.1 Site Restoration 173.1.1 Decommissioning
Objective:
To deliver Site End States as soon as reasonably practicable with a progressive reduction
of risk and hazard.
Government policy - The Decommissioning of UK’s The NDA estate includes reactors, chemical plants,
Nuclear Facilities (ref 6) states that ‘decommissioning research and development facilities, waste
operations should be carried out as soon as processing and fuel fabrication plants, many of
reasonably practicable taking all relevant factors which are redundant and all of which will require
into account’. These include safety, risk, security, decommissioning. Some plants date from the
environmental protection, funding, resources, 1940s and 1950s, such as the Legacy Ponds and
waste management, stakeholder views, skills, Silos at Sella!eld. These are deteriorating and contain
socio-economics and sustainability - noting that these signi!cant quantities of corroding radioactive waste,
align with our Value Framework. presenting our highest risk and our greatest
decommissioning challenge.
Legacy Ponds and Silos
Legacy Ponds and Silos comprise four main plants at Sella!eld which were used historically to prepare fuel
for reprocessing or to store waste. Radioactive materials have accumulated and remain since operations ended.
Over !ve decades the plant conditions have deteriorated and there is now increased urgency to reduce
the risk they pose. The facilities were not originally designed with decommissioning in mind so innovative
technology is being used to retrieve the radioactive material for storage in modern containment facilities.
Retrieved waste will be managed in accordance with our Integrated Waste Management Strategy.
The Pile Fuel Storage Pond at Sella!eld
18 3.1.1 DecommissioningOur Strategy
We will decommission our sites as soon as reasonably Beyond the options for deferred or continuous
practicable, but case-speci!c decisions will be made decommissioning there are two strategic sub-options
on when and how this is achieved. Decisions will take for managing the products of decommissioning: leaving
account of lifecycle risk to people and the environment, parts of a facility in place and regarding them as having
and other relevant factors to determine whether been disposed of (in-situ) or removing them for disposal
continuous or deferred decommissioning is the most elsewhere (ex-situ). Further discussion on the in-situ
appropriate strategic option: and ex-situ sub-options can be found in the SEA.
— continuous decommissioning Our approach to decommissioning is in"uenced
commences at the end of operations and strongly by the Waste Hierarchy and the products
continues until !nal demolition of the plant/ of decommissioning will be managed in accordance
See p38 facility/installation with our Integrated Waste Management Strategy,
including the segregation, treatment, conditioning
— deferred decommissioning
and packaging of wastes. Conversely, the timing and
comprises one or more periods when the plant/
method of decommissioning will in"uence our waste
facility/installation is purposely kept in a state of
management requirements such as waste processing,
Care and Maintenance as part of the programme
interim storage, waste treatment routes and the need
for achieving the Site End State.
for storage and disposal facilities.The two strategies
Both options have been shown by the Strategic are highly interdependent.
Environmental Assessment (SEA) (ref 3) to offer
To reduce risk and hazard we will de!ne and use Interim
long-term environmental bene!ts with continuous
States. These are natural milestones and decision points
decommissioning potentially providing the greatest
in the site restoration programme that lead us towards
bene!t. Where risk is the dominant relevant factor our
achieving a Site End State. Decommissioning may give
priority will be to continuously decommission until the
rise to Interim States where risk or hazard has been
risk is at least tolerable. This risk management approach
reduced to achieve a more stable condition.
applies to Legacy Ponds and Silos at Sella!eld which
See p59 represent an intolerable risk for the estate and are Our Asset Management Strategy is a key enabler,
therefore our top decommissioning priority. designed to ensure that the long-term net level of risk
posed by our estate does not increase.
We will manage the condition of our plants and
facilities to ensure that currently tolerable risks do
not increase to become intolerable and that all risks
are kept As Low As Reasonably Practicable (ALARP).
Development
This strategy is in development. We have engaged review of a strategic option, which may lead to a
with Site Licence Companies (SLCs) and Regulators, change from continuous to deferred decommissioning,
and explored national and international experience or vice versa.
and good practice. We have reviewed our !ndings
To support the SLCs in implementing this strategy we
against NDA requirements and will work to further
are developing estate-wide good practice guiding
underpin the strategic options and sub-options. We
principles. These principles and the relevant factors
will develop a comprehensive and consistent set of
inform and guide option selection when SLCs are
relevant factors for consideration during decision-
planning their decommissioning activities and
making, and will ensure that the rationale behind any
preparing Lifetime Plans (ref 5).
decision is clear. Work is also needed to capture the
circumstances and conditions that may trigger the
Delivery
Our current planned decommissioning strategies are ability of future generations to meet their own needs,
embedded in the Lifetime Plans (ref 5) being delivered or other liability holders to deliver their plans, such as
by our SLCs, for example deferred decommissioning MoD or EDF Energy. To aid restoration we will ensure
of the Magnox reactors. The assessment of options that our SLCs characterise their plants or facilities
and sub-options at site level must take account before they commence decommissioning.
of impacts on the Site End State and potential
We will commence Post Operational Clean Out
restrictions on future land use. The decommissioning
(POCO) on cessation of operations in order to deliver
objectives and Site End State for each site are given in
ef!cient and effective decommissioning, unless
Appendix C.
exceptional circumstances justify deferral.
We will continue to review SLC decommissioning
plans to ensure they remain aligned with our strategy,
deliver value for money and do not compromise the
3.1.1 Decommissioning 193.1.2 Land Quality Management
Objective:
To ensure that land quality is managed to protect people and the environment.
Land quality management involves managing risks Our challenge now is to demonstrate that risks are
to people and the environment from radioactive being managed appropriately and to prevent them
and non-radioactive contamination in ground from increasing as a consequence of, for example,
and groundwater. Each of our sites has some the migration of contamination. We must also
contamination as a result of various land uses, not determine the most appropriate way to manage large
all of which are associated with nuclear operations. volumes of lightly contaminated material that represent
Sella!eld is by far the biggest challenge. a signi!cant liability for the NDA. The volume of ground
estimated to be radioactively contaminated is around
The NDA Strategy (2006) (ref 1) focused on
ten times greater than the Low Level Waste (LLW)
accelerating the characterisation of land and
disposal capacity currently planned for the UK.
developing fully costed and robust long-term
management plans. That approach has been applied
and all SLCs now have an improved model of land
quality and have developed or are developing land
quality management plans.
Our Strategy
The !rst principle of the Waste Hierarchy, described in It is essential to predict if and how risk will change
See p38 the Integrated Waste Management Strategy, is to with time. At lower levels of risk, it may be better to
prevent waste creation wherever possible. It follows intervene promptly to prevent the problem worsening
that the !rst rule of land quality management is to and becoming more dif!cult and costly to resolve. For
prevent the contamination of ground and groundwater some areas of contamination the risk will decrease
- prevention is better than cure. This applies throughout with time as a consequence of naturally occurring
the lifetime of a site from facility design, through asset physical, chemical and biological processes. In
management to decommissioning, by avoiding new these cases, it might be appropriate to leave the
land contamination and controlling sources that already contamination where it is and make use of a process
exist. However, we recognise that leaks and spills have called Monitored Natural Attenuation rather than
occurred in the past. It is essential we fully understand intervene.
the problem through effective characterisation to
As levels of risk decrease, the Waste Hierarchy has
further reduce uncertainty in site plans for managing
greater in"uence on decisions about how best to
land quality and to ensure that remedial action is
manage land quality. In this context, our strategy
proportionate to risk, now and in the future.
is to maximise re-use of material and minimise the
Risk to people and the environment is our primary volume being excavated and disposed of as waste.
and enduring consideration in deciding how to Furthermore, the SEA identi!ed that detrimental
manage land contamination. How we manage this risk effects of land quality management are mainly
depends on the nature, extent and likely behaviour of associated with ex-situ solutions where the !rst step is
any contamination and therefore requires a case- to extract the contaminated material from the ground
speci!c assessment. Our strategy is to employ early prior to treatment for re-use or disposal. Therefore,
risk-based decision-making. because intervention may do more harm than good,
there may be situations where it is preferable to
At higher levels of risk there is less "exibility in the way manage contamination in-situ. This could involve
we manage land quality; the decision is driven by the controlling contamination or using in-situ remediation
need to reduce risk. Action will be taken as soon as techniques including Monitored Natural Attenuation
reasonably practicable to minimise the time at risk. to restore the land. We will explore opportunities for
managing contamination in-situ while still achieving the
level of restoration required for the Site End State and
to release land for other uses.
20 3.1.2 Land Quality ManagementDevelopment
This strategy is in development. To justify our Secondly, as part of our strategic R&D programme
See p57 approach to land quality management and build (see Research & Development Strategy), we are
stakeholder con!dence, it is important that we working with key stakeholders to develop a consistent
demonstrate our understanding of site conditions approach to risk assessment for radioactive and
and the level of risk posed by land contamination. non-radioactive land contamination. This builds on
Consequently, we focus on two key areas of work. existing methodologies and incorporates relevant
Firstly, we are revising our instructions to SLCs on national and international standards. In time, we intend
the reporting of land quality and the associated that this development work will be referenced in our
management plan (including an input to the instructions to SLCs.
See p38 Integrated Waste Management Strategy).
Delivery
SLCs will deliver the strategy through early appraisal of While options are being appraised, SLCs will continue
options for managing land quality on a case-speci!c to monitor land contamination and maintain !t for
basis, referring to established good practice and purpose records of land quality (see Information and
See p63 guidance. Decisions must be fully underpinned by a Knowledge Management Strategy).
sound understanding of the problem to ensure action
To ensure consistency in strategy delivery we convene
is timely and proportionate to risk. The options
regular meetings of land quality management experts
appraisal will take account of technical feasibility and
from the nuclear industry. These meetings provide an
lifecycle impacts on people and the environment,
opportunity for the NDA, SLCs and representatives
including appropriate application of the Waste
from other nuclear operators such as the MoD, EDF
Hierarchy. The resulting site land quality management
Energy and the Atomic Weapons Establishment (AWE)
plans will also accommodate the in"uence of other
to share lessons learned. They also explore common
strategies and site activities. For example, assessing
research requirements (acting as a subgroup to the
options for managing land contamination must take
Nuclear Waste Research Forum), examine potential
account of impacts on the Site End State and
shared solutions, discuss requirements for skills
potential restrictions on future land use.
development and, where appropriate, arrange training
workshops.
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