The Office for Nuclear Regulation (ONR), an agency of the Health and Safety Executive (HSE), has reviewed the Atomic Weapons Establishments (AWE's) strategy for nuclear decommissioning on the licensed sites at Aldermaston and Burghfield.
The ONR was created on 1st April 2011, incorporating the HSE's former Nuclear Directorate (ND) which included the Nuclear Installations Inspectorate (NII), Office for Civil Nuclear Security (OCNS) and UK Safeguards Office.
In carrying out the review, the ONR consulted with the Environment Agency for England and Wales (EA) and the Defence Nuclear Safety Regulator (DNSR) of the Ministry of Defence (MoD). The review discharged the duty contained in government policy (Cm2919) updated in September 2004, for HSE to periodically review the decommissioning strategy of each UK nuclear licensee.
Our review considered the adequacy of AWE's position, informed by the findings of a previous regulatory review, current legislative requirements, developments in best practice and government policy. Background information is presented to place AWE's strategy into context, to explain the full scope of strategic drivers and deliver the principles of Better Regulation. Our review contains actions on AWE to strengthen and implement its strategy.
The requirement for Quinquennial Reviews (QQRs) originated from the 1994 Nuclear Policy Review, first described in the original version of Cm2919 in 1995. At that time HSE wrote to all UK nuclear licensees requesting strategies for the purpose of a suitable review and outlined its approach to carrying out QQRs as part of Guidance to Inspectors on Decommissioning in 2001. The first review of AWE's strategy was published in December 2003. AWE made a submission to inform our latest review, which the regulators received in December 2007. This review has considered the adequacy of AWE's strategy against the criteria that applied at the end of 2007 but in framing the recommendations for further work, the review has taken account of changes that have happened since 2007 in order to ensure that the resources of AWE and the regulators are appropriately targeted at moving forwards.
ONR has concluded that AWE's strategy is appropriate. Since the last review, AWE has delivered a significant amount of decommissioning and strengthened the quality of its plans for future decommissioning projects. AWE has developed an Integrated Waste Strategy (IWS) and provided annual updates to its IWS since 2007. AWE has proactively sought to ensure that its approaches to stakeholder engagement, planning and execution of decommissioning are aligned with UK good practice. AWE has greatly reduced previous uncertainties about the nature and extent of radioactively contaminated ground at Aldermaston and developed a comprehensive strategy for its future management.
Since 2003, several relevant changes have taken place in government policy for the country's nuclear deterrent and nuclear decommissioning. Our review has sought evidence that AWE has kept its strategy up-to-date in response to these external changes.
In terms of defence policy, AWE's strategy was previously based on the 1998 Strategic Defence Review (SDR), which stated AWE would retain the capability to service the pre-existing UK stockpile of Trident missiles for the remainder of their anticipated operational life. This position has been updated by the White Paper Delivering Security in a Changing World (Cm6041-1, December 2003); by the major AWE investment program announced in Parliament in 2005; by the White Paper The Future of the UK's Nuclear Deterrent (Cm6994, December 2006) and most recently Securing Britain in an Age of Uncertainty (Cm7948, October 2010). As a result, over 100 buildings have been demolished and development of several major new facilities has commenced.
Major changes have also taken place to government policy for nuclear decommissioning and the structure of the UK nuclear industry. Creation of the Nuclear Decommissioning Authority (NDA) under the terms of the Energy Act 2004 was followed by revisions to policy for the long-term management of solid Low Level Waste (LLW), solid Very Low Level Waste (VLLW) and decommissioning (via updates to Cm2919).
HM Government has supported the recommendations of the Committee on Radioactive Waste Management (CoRWM) and progressed the Managing Radioactive Waste Safely initiative for long-term management of higher activity radioactive wastes. The former Nuclear Industry Radioactive Waste Executive (NIREX) has been reconstituted to become the Radioactive Waste Management Directorate (RWMD) of the NDA and given responsibility to develop a deep geological disposal facility.
In 2005 new guidance was published on the NIA65 No Danger criterion, which clarified the HSE policy that site operators need to satisfy in order to de-license a nuclear site on completion of decommissioning. In 2006 HSE revised its Safety Assessment Principles (SAPs), introducing new principles for the management of radioactive wastes, decommissioning and the management of radioactively contaminated land.
The MoD is developing an over-arching national level strategy for the management of all liabilities associated with the MoD's nuclear programme; it will be important for AWE's plans to be consistent with the MoD's developing approach.
AWE made a submission to the regulators to inform our review. The submission gave a commentary on progress in meeting the recommendations from the previous QQR and further evidence of improvements. Our review has considered this evidence alongside other data, including intelligence gained from routine regulatory interactions.
AWE is working to comply with a formal HSE Specification on ILW storage at Aldermaston; the associated projects are the subject of ongoing and extensive interactions between AWE and the regulators.
AWE has changed its LC35 compliance arrangements, with an impact on the way work on nuclear liabilities is managed and reported on. This has secured clearer managerial responsibilities, with regular updates provided to the regulators in a systematic and quality assured manner. The new arrangements have allowed the regulators to select hold points in AWE's plans and monitor AWE's delivery via the Level 3 Regulatory Interface Meeting (RIM).
AWE has already delivered a significant amount of decommissioning, due to the vintage of its plant and the need to clear space to facilitate the regeneration of Aldermaston. The future management of some liabilities is still subject to uncertainty; AWE is undertaking options studies on future plans to deal with specialised materials that present particular technical and logistical challenges, including the legacy of Wastes Requiring Additional Treatment (WRAT). This work continues to be the subject of regular engagement between AWE and the regulators.
AWE has produced Series III Outline Decommissioning Plans (ODPs) for all existing nuclear facilities and purchased Primavera software to provide an overarching interactive cross-site decommissioning plan. A sampled assessment of ODPs and outputs from the Primavera system has found some ways in which AWE's current approach could be strengthened, replicating some lessons learned on the NDA estate.
ONR will consider all relevant factors in reaching a decision on the format and timing of future reviews of AWE's strategy. Specific areas of interest are: The status of decommissioning at AWE; further developments with AWE's decommissioning planning systems; improvements to AWE's LC35 Compliance Arrangements; the MoD's development of a liabilities management strategy covering its entire nuclear programme, and; any forthcoming changes to government policy including Cm2919.
ONR will proactively engage with both AWE and the MoD as the above arrangements move towards a state of greater maturity.
In order to obtain the full Assessment Report that has informed this summary please contact ONREnquiries@onr.gov.uk quoting the following:
HM Chief Inspector of Nuclear Installations
Office for Nuclear Regulation