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UKAEA’s mission is to restore the environment of its sites in a way which is safe and secure, environmentally responsible, publicly acceptable and gives good value for money. This is similar to the role described for the LMA in the White Paper.

However, by assuming a national role, including the BNFL sites as well as UKAEA’s, UKAEA sees the LMA bringing advantages. It will allow site restoration programmes to be integrated, co-ordinated and prioritised at national level, not just within a single company as UKAEA has been able to do. A national strategy, developed by the LMA in consultation with the regulators, covering all UKAEA and BNFL sites, will help to achieve a consistent approach and reduce duplication between sites.

We welcome the commitment to generic research; this will be much more effectively delivered across the programme as a whole than by individual licensees.

We do need to attract more young people into the industry. We hope the White Paper will be a spur to achieving this.

Nuclear site restoration has been UKAEA’s core business for the past eight years. We are proud of what we have achieved, which we have summarised in the attachment, and we are pleased that the White Paper has appropriated our principles and values for the LMA.

Nevertheless, nuclear site restoration has been the Cinderella of the nuclear industry. We look forward to the LMA raising the profile of nuclear legacy management, recognising it as a programme of national importance and giving it real impetus.

We believe that the title of the new organisation should be reviewed. ‘Liabilities Management Authority’ is both negative and obscure and does not express the benefits we expect from the new body. The UKAEA strapline ‘Restoring the Environment’ has been enormously beneficial both in explaining what we do to third parties and in giving our employees real pride in their job. The LMA might consider ‘The Nuclear Environmental Restoration Authority’.

Impact on UKAEA

The White Paper raises questions about the long term future of UKAEA. We welcome the opportunity to demonstrate that we should be the supplier of choice to the LMA for the management of our current sites. We also welcome the opportunity - if we deliver, as we intend to - to develop relationships with private sector companies to improve management of UK liabilities as a whole.

We expect the LMA to base its decisions on UKAEA as a supplier of choice on demonstrable performance against clear objectives and criteria. We look forward to contributing to the development of these performance criteria, and welcome the government’s indication that contracts will probably be of 5 to 10 years duration, allowing us time to demonstrate that we can deliver the required results.

We support the decision not to change the operating structure of UKAEA or the ownership of its sites unless and until there is a clear need to do so.

It is essential that the introduction of the LMA causes no disruption to our programmes of work. We welcome the open approach of the Liabilities Management Unit, and have been pleased to co-operate with its staff in developing their thinking. However, we must not be distracted from delivering our decommissioning plans - in particular, the Dounreay Site Restoration Plan - either by the excessive diversion of management attention towards LMU/LMA issues or by the need to divert funding and resources towards the development of new processes required by the LMA.

We welcome the commitment to long term funding for the programme which will be essential to give confidence to all stakeholders that government is committed to getting the job done. This will help to optimise plans, develop a healthy supply chain, encourage companies with relevant skills to get involved in the programme and will thereby ultimately improve value for money.

The commitment itself is of more importance than whether it is implemented through a Segregated Fund or a Segregated Account.

We expect the LMA to review the present clean-up programmes. UKAEA plans are based upon the decommissioning policy in Cmnd 2919, as interpreted between ourselves and the NII, and optimised at a 6% discount rate. We understand that Government is currently reviewing both Cmnd 2919 and the discount rate which should apply to long term programmes and we would expect to review our programme should different criteria be adopted.

Some outcomes may require more short term funding to provide greater long term pay-off. We assume that if this were the case, funding would be available through the segregated arrangements or could be obtained from the private sector on value for money grounds.

We welcome the emphasis on a healthy market. UKAEA’s approach of competing most of the implementation work depends on a healthy contracting market. Expanding the market for decommissioning contractors will create a much healthier competitive market place than UKAEA’s programme could achieve on its own.

To succeed, the LMA must develop a consensus with site licensees and the regulators on the interpretation of decommissioning policy and on the standards for land remediation and delicensing. Uncertainties in these areas make it impossible for licensees to define the end points of their programmes and therefore their total scope and cost. Without consensus, licensees will be pulled in different directions by the different views of regulators and government about the right policy and strategy.

Agreement must also be reached on discharges with the safety and environmental regulators. It is not possible to decommission facilities without generating discharges to the environment, however small. A balanced approach to the levels of discharges from decommissioning works must be established between the regulators and the regulated.

Similarly the costs of risk abatement should be proportionate to the risks involved.

A shared view on end-points, rates of progress, standards, and agreed protocols for regulatory approval is essential to allow licensees to commit to programmes of work, the LMA to write robust contracts and us all to achieve a clean-up programme with clear purpose and momentum.

We look forward to being able to comment on the draft Memoranda of Understanding which will govern the relationships between the LMA and the regulators in these areas.

It is important that DEFRA completes its consultation on long term nuclear waste management expeditiously. It will not be possible for licensees properly to plan, scope or cost their programmes, until a policy decision is made and clear and practical guidance is provided.

The issue of which institutions should deliver the long term waste management policy is secondary. There will be a continuing need for the research and packaging roles currently provided by NIREX and for the NIREX database. However, the creation of the LMA provides an opportunity to rationalise responsibilities in this area, bearing in mind that there is a continuum between decommissioning and waste management.

The contracts between the LMA and the site licensees must take proper account of the uncertainties inherent in these programmes of work. Factors such as lack of detailed records, deterioration in plant conditions over time, and changing regulatory requirements will require proper consideration to establish a fair and proper balance between the LMA and its contractors.

The contracts should not drive licensees to deliver an agreed programme even when new knowledge, new technology, regulations or ideas have revealed it as sub-optimal. Conversely, they should encourage licensees to propose programme improvements which have longer term benefit outweighing adverse impacts over the period of the current contract and which require changes to the current plan.

We hope that there will be a clear line of demarcation between the LMA’s responsibility for strategy and the licensees’ for delivering the programme. The licensees should be allowed to get on with the job without day to day intervention in management detail by the LMA.

We support the proposals for the UKAEAC. Our interest is in continuing to receive an effective policing service, not in retaining the Police as part of UKAEA.

We welcome the proposal that the licensees will have a majority on the Police Authority, reflecting our responsibility for security at our sites and for funding.

We very much support the reassurances given about pensions. We also support the proposal to retain pension continuity for employees even if their employer should change.

We have already made clear our desire to offer UKAEA’s Thurso Pensions Office as the administrator of any new schemes. Both the Quinquennial Review of UKAEA and customers have commended the Office for its quality of service and value for money. It is a valued employer in Thurso. It is well placed to take on a broader role.

Denis Tunnicliffe
Chairman
United Kingdom Atomic Energy Authority
18 October 2002

Attachment - UKAEA’s Achievements