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WEST CUMBRIA SITES STAKEHOLDER GROUP COMMENTS ON THE NDA’S DRAFT BUSINESS PLAN APRIL 2017- MARCH 2020.

This document captures the views and thoughts of the West Cumbria Sites Stakeholder Group (WCSSG) on the Nuclear Decommissioning Authority’s draft Business Plan currently out for consultation.

The contents of this report are a result of collaborative engagement with the six working groups that support the main WCSSG and incorporates the views of each of those groups. Feedback from those individual groups, although summarised within this response, has also been included as appendices at the end of this document.

Contents:

1. Executive Summary Page 22. Introduction Page 23. Consultation and timescales Page 34. Positive Aspects of the draft plan Page 35. Areas for improvement Page 46. Conclusions Page 77. Appendix 1 – R&HR&WM working group Page 88. Appendix 2 – SFM&MN working group Page 99. Appendix 3 – Emergency Planning working group 110. Appendix 4 – Environmental Health working group Page 1211. Appendix 5 – Low Level Waste Repository working group Page 1312. Appendix 6 – Enablers working group Page 16

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WEST CUMBRIA SITES STAKEHOLDER GROUP COMMENTS ON THE NDA’S DRAFT BUSINESS PLAN APRIL 2017- MARCH 2020.

1. EXECUTIVE SUMMARY.

The WCSSG is grateful for the opportunity to comment on NDA’s draft plan. It has enabled us to raise the issues which are important to us – we represent the host community which houses the vast majority of the country’s nuclear waste and spent nuclear fuel. We have highlighted a number of positive areas of the draft plan, but also identified a significant number of areas where we believe important changes, or additions are required before final publication in order to:

1.1 Provide a clear and common understanding of the purpose of the plan.1.2 Ensure the full scope of NDA’s activities are covered appropriately; currently issues

which are important to us are barely mentioned.1.3 Provide specific delivery targets in each of the key activity areas, so that the SLC’s, and

ourselves, are very clear on NDA’s specific key objectives for the next three years.1.4 Provide more focus and detail on the way NDA will manage and improve the socio-

economic effects of their sites activities on the communities in which they operate.

2. INTRODUCTION.

This note summarises the comments made by the WCSSG on NDA’s proposed Business Plan for the period April 2017 to March 2020. During the consultation period for the draft plan, working groups of the WCSSG have considered and commented on NDA’s proposal and the Enablers Working Group has consolidated those comments into this summary document, which was communicated to NDA in final draft form during the consultation period, before consideration and formal approval at the full WCSSG on 7/02/2017. Specific more detailed comments from the Working Groups are included as appendices to this summary.

In providing these comments the WCSSG has not attempted to get into the fine detail of the plan. We are grateful for the opportunity to comment, and see the process as a natural progression from the comments we made on the adequacy of NDA’s draft Strategy III published in 2016. We have considered whether the plan is adequate to help NDA deliver their Strategy in the manner articulated by the NDA’s current CEO on page nine of the draft plan i.e. “remediation of all NDA sites in a safe, secure, environmentally sensitive and cost effective manner, always seeking opportunities to accelerate work, where this can be done effectively”. Perhaps understandably, our focus has been restricted to the West Cumbrian Sites and largely to Sellafield, which houses one of the largest nuclear fuel and active waste inventories in the world. We are, and will remain, the host community for this material for many decades, until the Government finally selects a site(s) for Higher Active Waste disposal, decides upon its waste disposal plans, and then implements them. Our communities will continue to be exposed to the risks and impacts, both good and bad of West Cumbrian site operations throughout this period. In this context we have a reasonable expectation that our views and opinions will be sought and responded to, if not acted upon. If they are not it will simply increase the growing feelings of frustration, which a number of our members have expressed, that important decisions are being taken by both Government and central organisations without due consideration of the impacts upon the associated communities. In this context we request a response from NDA to the specific comments we have made in this document.

3. CONSULTATION PERIOD AND TIMESCALES.

The consultation process the NDA has chosen ran for 8 weeks from 12/12/2016 to 3/02/2017 and contained the fortnight spanning the immediate approach to Christmas and the aftermath of New Year. The timing and duration of the consultation are unfortunate and have made it very difficult for the WCSSG to formulate a response. We are a relatively large, disparate, Group, with a fixed meeting diary and comprises of people who voluntarily give their time freely and willingly, but who have many other demands to meet. In this instance we have been helped by early engagement from NDA and this enabled us to get organised before the start of the consultation period. We were however hampered by the unwillingness of Government to allow NDA to informally release draft information to us slightly in advance of the start of the formal consultation. We would urge NDA in the future to help community groups by considering improvements to the timing and/or duration of the consultation period and to continue their practice of early informal engagement but to compliment this by early release of draft information and trusting us to deal with it appropriately.

4. POSITIVE ASPECTS OF THE DRAFT PLAN.

In reviewing the draft plan the WCSSG working groups made a number of positive comments about its layout and content. These are summarised briefly below, they represent aspects which we believe the NDA should repeat and build upon in future issues of the plan:

4.1 The plan is generally well structured, of about the right size, and flows through from NDA’s key activities into more detailed plans, in a logical manner.

4.2 The language used is relatively simple to understand, if at times a bit imprecise (see later). This understanding is aided by appropriate use of illustrations and also the use of a colour scheme for key activity areas, which is consistent with that used in Strategy III.

4.3 The 20 year Priority Programme Overview, presented on pages 16 and 17, is a useful tool to aid understanding of the “big picture” of NDA’s key activities and how they link together.

4.4 Financial data presented on pages 18 to 20 is a clear overview and we have already congratulated NDA on their performance in securing an appropriate level of funding at the last Government spending review. We are pleased to see that priority is being given to Sellafield (⅔ of total spend over the three year plan period) because of the significant number of very high hazard plants that require waste remediation. This prioritised spending must be maintained until risks are reduced, indeed we believe that, on a risk reduction basis, there are some arguments that expenditure should be increased, providing this can be done in a cost effective manner.

4.5 Most of the key activities relating to operational activities at Sellafield, which we believe are important to be delivered, are addressed in pages 24 to 26. There are some omissions, which we believe it is important to consider and rectify and these are outlined in detail in the next section.

4.6 The plan addresses safety, security and environmental issues at a high level, giving a commitment to encourage the delivery of the highest standards of safety, security and environmental responsibility. It also commits NDA to reducing environmental risk and minimising discharges in line with UK discharge strategy. We would have appreciated a little more detail in these areas and have commented to this affect later in this document.

4.7 The non-site summaries, for NDA and its subsidiaries, presented on pages 38 to 43 are a useful insight of the full scope of NDA’s activities (an improvement would be the addition of some key milestones for the subsidiaries later in the document)

5. AREAS FOR IMPROVEMENT.

There are a number of areas where we believe the plan is not as clear as it needs to be or where there are apparent gaps in scope and content. These are summarised below:

5.1 We would have appreciated a brief but comprehensive “purpose statement” for the plan which made it clear what it was trying to achieve and how. On page 12 the “Plans” section notes that its purpose is to “set out the key activities for the NDA and the estate over the next three years …..” Our expectation is that the NDA will set challenging targets for its Site License Companies, for the three year period, on what it wants them to achieve, and then both support, challenge and hold the SLCs to account to deliver them. We don’t believe there is enough specific detail on NDAs targets in the plan to demonstrate to us this can be done effectively.

5.2 We would have appreciated a short statement on how lessons from last year’s plan had been built into this plan in order to reduce errors and spread success, we wish the NDA to demonstrate they are a learning organisation who are continually improving. As an example one reason for the successes at LLWR has been the positive values and behaviours demonstrated by NDA/ PBO / SLC/ workforce and our community and these should be reinforced and built upon.

5.3 On the estates operating diagram it would be useful to illustrate the position of PBO as well as the SLC.

5.4 Pages 12 and 13 of the draft plan present what NDA do in headline terms. The draft plan subsequently focusses on operational activities across the estate but is either silent on, or barely mentions, the key activity areas of Research and Development, Socio-economics and Skills. These areas are of particular interest to us (see later). The full scope of NDAs activities are not adequately addressed in the plan, we would expect the plan to address this full scope in its final form.

5.5 There are some details in the 20 Year Overview which confuse us. Evaporator D is shown to be taken out of use at the end of 16/17? We are concerned that The HA evaporation and storage plants and the vitrification lines are POCO’d and taken out of use by 2024/25 – we believe these are key strategic assets that may need to support waste remediation and site decommissioning for much longer than this. The section Higher Activity Waste management implies that site selection of a GDF took place at the end of 2014/15, when this is clearly not the case. Indeed some members questioned why this activity was included since it is not yet part of the NDA estate but an RWMD activity. What does appear to be missing is the work stream that NDA are championing on integrated waste management and the significant amount of work that NDA needs to carry out to ensure the Site License companies demonstrate their waste will be suitable for eventual disposal in the GDF. Additionally, we do not understand why AGR fuel receipts are included in this section, when they are not yet classified as a waste. We expected to see a work stream relating to the significant change of use of Pond facilities at Sellafield, from supporting reprocessing to the ongoing storage of AGR fuel for many

decades. The new LLWR contract is due to start in April 2018 so we would have expected a contact decision well in advance of that date.

5.6 We would like to understand how the Sellafield and LLWR related spend is broken down into key areas and phased over the three years, so that we can see how specific site activities are being prioritised and funded. We would also like to understand why expenditure on Research and Development, Socio-economics and Skills development has reduced compared to the 2016/17 plan. Given the significant challenges to be faced in these areas and their importance to our communities, we expected expenditure to increase significantly. We don’t understand how this expenditure relates to that spent in these areas by the Site License Companies, is this additional expenditure or part of the same overall total?

5.7 We note that the vast majority of NDAs income in 2017/18 will be generated by Sellafield related activities, i.e. reprocessing and waste and fuel management, and the proportion will increase in 2018/19 and 2019/20. We would like to understand how this income will vary over the next 10-20 years so we can understand how the taxpayer’s financial burden will increase, and where and when we may need to act proactively to support NDA in securing adequate funds to ensure an acceptable ongoing rate of risk reduction at Sellafield.

5.8 Pages 22-23 list 22 Key Activity areas for Sellafield, we would agree that most important areas are covered. However we were disappointed to see that no specific key performance dates or targets are specified by NDA, the majority of key activity entries require things to “be started” or to “continue”. Given that the total expenditure in these areas and periods represents approximately £6 billion we would have expected to see quantified targets to be specified in each key area. This would both give some quantified guide to Sellafield Limited on NDA’s requirements (and form the basis for subsequent discussions on more detailed performance management arrangements) and also allow the WCSSG to measure NDA’s performance against their declared targets and then support, congratulate or challenge them as appropriate.

5.9 Similar comments relate to the enabling activities listed on page 24. We would like to understand where we can see the more detailed plans that NDA has produced, or will produce for each of the key activities of socio-economics, skills development, Research and Development and supply chain improvement, noting that the Energy Act places specific accountabilities upon NDA in these areas. The detail currently presented in this section is inadequate to allow us to understand what NDA is actually aiming to deliver, over the three year period, and how that will impact on our Communities.

5.10 The first entry in the enabling section relates to a programme of site security and resilience enhancements, Whilst we are pleased to see this focus we cannot tell what is covered (CNC, Guard Force, Cyber security, Fire and rescue, Site perimeter fence and gate enhancements?), what the targets are and consequentially what is being spent and from where it is funded (Sellafield, NDA, Government?), Without such information we cannot judge how NDA is performing and whether this constitutes value for taxpayers money.

5.11 We would not necessarily expect this document to set detailed targets or standards, for environmental performance, these would be best contained in Site License Company plans. However we do believe that NDA should visibly commit in the plan to delivering “an open and transparent approach” to managing future discharges from the significant site remediation and risk reduction projects which will begin at Sellafield during the next 20 years. This approach should be very clear on how NDA will interact with their SLCs to

ensure inevitable effluent discharges will be controlled and mitigated in order to reassure the local communities that Best Practicable Means approach will be adopted and consequently engender their support and trust.

5.12 There would be some benefit in highlighting NDA’s intent to ensure sustained and effective community engagement well in advance of key strategic activities during the period of the plan, such as LLWR 3rd Contact decisions and the completion of AGR/ MAGNOX reprocessing.

5.13 We believe that a number of the activities shown as starting in 2018 on Page 24 are starting far too late. For example, given that Thorp reprocessing will cease in 2018/19 (and Magnox reprocessing shortly afterwards) we would have expected work to be underway now on preparing the business to move out of reprocessing, and delivering capability development/ organisational development at Sellafield. Our communities are facing a cliff edge reduction in employment numbers in these areas at Sellafield and, to help us fully understand the consequential impacts, we would request open and timely communications in this area from NDA’s plans.

5.14 We would like to see a work stream in the enablers section dealing with risk quantification and presentation. Our communities would like to understand how, with time, the risks they face are being reduced by the planned activities, or, where there is a justifiable short term increase in risk, to facilitate decommissioning or remediation activities, how the increased risk will be mitigated. Given that risk management and reduction is a key strategic objective of NDA, as outlined in Strategy III, we would have expected it to be given far more detailed consideration and visibility in these plans. We also believe external risks to plan delivery should be made more visible, for example the impact of Moorside developments and the inadequacy of local social and environmental infrastructure. In this context we would reiterate our comment on the draft Strategy, that we would expect NDA to require their SLC’s to produce transport plans which manage and minimise the impact that all transport associated with their activities has on the local community.

5.15 We have some concerns on the section dealing with RWM on page 40. The strategic approach in this area is based upon an assumption made by NDA that a GDF will be available by 2040. Given the lack of progress in this area over the last 30 years, we believe it is inconceivable that a GDF will be available on that timescale. As the current host community for the vast majority of the country’s higher level wastes and spent nuclear fuel, we would like to see NDA build and share at an early date, a strategy and supporting plans, based upon a range of viable GDF availability dates so the implications can be understood and managed. This strategy must also consider the significant quantities of spent fuel and plutonium which will require safe storage on site for decades pending identification and provision of a suitable disposal/reuse location. We wish to be reassured that the structural integrity of all ponds and stores, particularly those which will have a required life expectancy of 100 years or longer, will be managed in a manner which will facilitate timely remedial action and/or the relocation of their contents. Without this approach we cannot be certain we will not be exposing future generations to unacceptable risks equivalent to those currently posed to our communities by the legacy ponds and silos areas.

5.16 We would like to see more visibility given in NDA’s plans on how they can make best strategic use of the land they own. Land adjacent to sites may be crucial to support future site remediation, choosing appropriate end states will avoid excessive site remediation costs and both aspects are of interest to our communities. We also believe

that, for land more remote from the sites, there may be some benefits from the transfer of land to local communities.

6. CONCLUSIONS.

The WCSSG is grateful for the opportunity to comment on NDA’s draft plan. It has enabled us to raise the issues which are important to us – we represent the host community which houses the vast majority of the country’s nuclear waste and spent nuclear fuel. We have highlighted a number of positive areas of the draft plan, but have also identified a significant number of areas where we believe important changes, or additions, are required before final publication in order to:

6.1 Provide a clear and common understanding of the purpose of the plan.6.2 Ensure the full scope of NDA’s activities are covered appropriately; currently issues

which are important to us are barely mentioned.6.3 Provide specific delivery targets in each of the key activity areas, so that the SLC’s, and

ourselves, are very clear on NDA’s specific key objectives for the next three years.6.4 Provide more focus and detail on the way NDA will manage and improve the socio-

economic effects of site plans on the communities in which they operate.

- Ends –

Appendix 1

Summary of comments made by members of the Risk and Hazard Reduction and Waste Management Working Group regarding the draft NDA Business Plan for 2017 – 2020

The draft NDA business plan was discussed at the meeting of the Risk and Hazard Reduction and Waste Management Working Group on Wednesday December 21st 2016. A summary of the group’s feedback is included below.

NB: Minutes for the rest of the meeting will be published sometime in January probably.

General comment – it is good that all of the important things the group has mentioned in the past seem to have been included.

On p. 16, the timeline shows “Evaporator D” complete at the end of 2016/17. This ought to be reworded to avoid confusion, perhaps to “Commissioning of Evaporator D”.

Also on p. 16 in the other “Evaporator D” things (“Vitrification of Highly Active Liquor (HAL)” and “Reduction of HAL stocks”), this chart seems to suggest they will end in 2019/20. This is misleading.

Further down p. 16 – in the second section from the bottom (“Higher Activity Wastes (Inc RWM)”) – are those dates for the grey boxes (“Preparatory studies” and “Volunteer site surface investigations”) correct?

The key activities are too vague – for example on p. 22 “remove sludge from a set of wet bays” – how much sludge? Which bays?

pp. 22–23 – a lot of vagueries on the key activities. Excessive use of the word “continue”. pp. 22–24 – most of the key activities do not map to any current key milestones. There are gaps in the business plan, for instance R&D doesn’t seem to mentioned at all. It would nice if FHP was mentioned. Could some key activities be added in relation to FHP?

Appendix 2

Feedback from Spent Fuel Management and Nuclear Materials Working group on the NDA’s draft business plan – contents have been incorporated into the final response document

Page and section of business plan

SFM & NM working group joint response

Pg 13 – What we do No detail on what NDA are putting into place to make the ‘Socio-Economic’ goals/objectives deliverable by April 2017.

Nowhere is it clear how the actions in the business plan relate to (causality) achievement of those objectives. Can’t see the "read-through".

The four bullet points under socio economics are supposed to be an extension of what we have in place already. However, believe none of them exist.

As an aside, nobody knows what "socio-economics" is. I'm not sure there is such a word. The Act refers to "social economic and environmental benefits to the community" and that’s what we should stick with. For next strategy review maybe?

Pg 16 – 20 year Priority programme

Under HAWs (second bottom) the grey line shouldn't be there. That’s RWMD activity not SLC activity. The SLC activity (all sites) is to prepare and secure “stuff” on site before movement to store (at whatever location). There is no detail around what SLC’s need to do to prepare for final location.

What is the RWM part of NDA doing? Lacks focus on this as it needs to be more specific than ‘continue to’.

Pg 18 – Our Funding Lack of detail around the breakdown of costs, what is left for us and where/how the remaining funding will be used.

ACTION: Brian Hough to provide more detail on breakdown of costs shown on page 20 of Business Plan.

Clarity required on the R&D and Pension costs stated, is it NDA? (referenced in last paragraph)

Pg 20 - Our funding (Non-site expenditure)

More detail and clarity required on non-site expenditure (p20) especially break down the socio-economic, skills, R&D etc line.Again, clarity required on the R&D costs stated, is it NDA?

Why is GDF costs included if not yet agreed (as referenced on

p18)

Brian Hough advised that this includes work that RWM continue to do.

The document states a figure of £180m for other activities, the range they cover is far too broad and that the £31m for socio economics covers all 17 of the NDA sites is way too low.

Pg 23 – Key Activities What is the RWM part of NDA doing? Lacks focus on this.

It also needs to be more specific than stating ‘Continue to…’

Additional Comments: Would like to see the Plan accompanied by an external "Risk Register". As on-site internal risks are registered and covered, but there are external and contextual risks specific to Sellafield site eg impact of other developments like Moorside; public confidence in the commitment to "sustainable communities"; adequacy of local social and environmental infrastructure, etc.

Would also like to see the predicted workforce employment profiles for the next 10 years.

There is fading confidence from the local communities and a feeling that they have no control over their own future as decisions are being made nationally not locally and currently there is no place/ability to discuss or hold conversations with Government. There is a lot of frustration and clear lack of pulling all these issues together and presenting to Whitehall.

Appendix 3

Response to NDA Business Case from the Emergency Planning Working Group - 7 January 2017

The NDA Draft Business plan 2017–2020 clearly identifies critical enablers for the Sellafield Security and Resilience Enhancements Programme. We assume within this are the following:

CNC

Guard Force

Cyber Security

Fire & Rescue

Site perimeter fence and gate enhancements

The funding does not seem to be as straight forward as other funding and it is unclear whether it will come from the current site allocation or additional government funding.

Are CNC costs incorporated within the Site budget? Sellafield Fire and Rescue Service seem to sit within a directorate but still the funding is unclear. National issues such as Cyber Security are flagged as high priority. Are these funded from within the Site allocation or separately?

There is no form of benchmarking against similar operations to show the level of success. Without this and any audit or funding information, it is difficult to see whether this gives the taxpayer value for money.

The questions we would ask are;

How much is any of this going to cost.

Where does the funding come from? Within the site budget, or from additional government funds?

How will it be benchmarked and what against?

What audit processes are in place?

Yours sincerely

Appendix 4

Feedback from Environmental Health Working Group on the NDA’s draft business plan

There is really nothing in this about environmental protection standards apart from the paragraph on page 13 which refers to a 'commitment to encourage the highest standards of safety, security and environmental responsibility'.

There is nothing concrete one can draw from this, as there is no marker laid down for what is 'highest' and there is only a 'commitment to encourage', not to achieve.

I do have some sympathy with the NDA on this as it is hard to set specific objectives or performance measures in an overview document of some sort. The delivery of 'an open and transparent approach to secure the support and trust of our stakeholders' could be an important element though.

At the level of specific sites, in our case Sellafield and LLWR, it would be helpful to begin to see some more specific information on the environmental implications of the changing nature of the processes, particularly at Sellafield.

The plan helpfully sets out on pages 23 and 24 the key activities at Sellafield through to 2020, and refers to 'reducing environmental risk' and to 'minimising discharges in line with UK discharge strategy'. However even these statements don't give any measurable standards of success.

Although probably too detailed for this document, I think it would be helpful to give stakeholders more advance insight into future levels of discharge from the site (a presentation on which I hope we will get at the May EHWG) and for each of the major decommissioning or risk reduction projects, such as Magnox Swarf Storage Silo emptying, an outline of how the inevitable additional arising of effluents from them are to be controlled (and minimised).

This would contribute to real delivery of 'an open and transparent approach to secure the support and trust of our stakeholders', and it should be possible to find some words in the Business plan to reflect this approach.

Appendix 5

LLWR WORKING GROUP COMMENTS – 18/01/17

PAGE COMMENT SUGGESTION ENABLER GROUP RESPONSE

10 How the Estate Operates - diagram and commentary does not reference PBO model or role of regulators.

Consider including a reference to PBO and regulatory framework in narrative and/or diagram.

Not captured in note

14 Magnox Reactors and Magnox Reprocessing – Wylfa due to complete defueling in 2018 and Calder Hall in 2019 with fuel transferred to Sellafield for Reprocessing. Magnox reprocessing due to finish 2020.

Consider adding a comment to end of Magnox reprocessing section that caveats “subject to defueling of Wylfa and Calder Hall achieving their target dates”


15 Contract decision for LLWR in 2018 – Third term to commence 1st April 2018 so announcement of that decision in 2018 seems late, would have expected the date to be sometime in 2017.

Consider changing lead para to “contract decision 2017” or “contract commencement 2018”


18 Funding framework – states planned expenditure voted upon annually – CSR funding set for 3 or 4 consecutive years.

Consider clarifying this sentence to avoid confusion.


18 Commercial Income – refers to income volatility due to ageing assets and infrastructure.

Consider acknowledging cessation of reprocessing which is an income generator and a contributor to income volatility.

Captured but not specific to reprocessing.

19 Summary of NDA funding – significant year on year increase in income (almost £100M) yet reduction in 2016/17 of £70M

Explanation of increased income forecast would be beneficial

Captured

23 Site Summaries Sellafield – no major milestone indicated for Magnox reprocessing yet THORP is highlighted.

Consider adding milestone. Not captured in note

25 Site Summaries Magnox – refers to 12 sites but on page 14 narrative refers to 11 sites

Inconsistency Not captured in note

26 Key activities – no mention of Calder defueling but Wylfa is mentioned

Consider adding Calder Not captured in note

35 Site Summaries LLWR – Current key Milestone states 2080 final

Consider whether should caveat 2080 date as it will


site clearance when it is well publicised fact that ESC demonstrates 2130.

change in LTP18.

35 Site Summaries LLWR – Type B programme captured as a key milestone but should appear as a Key Activity

Consider changing. Not captured in note

42 NDA Properties – typo 3rd activity “off” instead of “of”

Typo Not captured in note

GENERAL COMMENTS FOR CONSIDERATION

POINT COMMENT SUGGESTION ENABLER GROUP RESPONSE

1) No milestones or activities for NDA

Consider including targets Captured

2) Plan would benefit from explaining that all SLC’s have their own plans with detailed information regarding spend and milestone dates

Consider reference to individual SLC plans to provide more detailed information

Captured

3) No milestone dates for subsidiary companies

Consider presenting in same format as for SLC’s

Referenced in note but not explicit

4) Stress funding secured for 3-4 years not just 1 year and the importance of a consistent approach to ensure key activities receive the level of funding required over the plan period. LLWR services and activities are key enabler for NDA estate decommissioning programme.

Covered for Sellafield but not for LLWR. Point needs strengthened.

5) The Socio-economic section on page 13 needs strengthened particularly with regard to bullet points 2 and 3 - diversification of local economies and increase attractiveness of areas. Stakeholders are critical about performance to date and sceptical about how these issues will be addressed.

Consider including a case study where these key tenets have been put into practice with successful results

Covered in note but consider strengthening.

Example given was NDA’s inability to support local authority/communities when campaigning over reductions in West Cumberland Hospital services and reluctance to engage/support infrastructure funding proposals when they are key to servicing the nuclear industry.

LLWR SPECIFIC COMMENTS

1) One of the key activities for LLWR is to continue to pursue positive SLC behaviours. This is borne out of a successful PBO/SLC relationship that has introduced core values and behaviours that are applied to all areas of activity whether it be work based or with the community. This approach has changed a workforce culture and community perception and enhanced LLWR reputation.

Embedding the right values and behaviours is important to all organisations.


2) Early community/stakeholder engagement with regard to a potential 3rd term for LLWR is crucial to building understanding and gaining acceptance to proposals ahead of reaching agreement of scope.

Consider adding a sentence specific to LLWR 3rd Term and potentially other important strategies/plans like SL socio-economic plan

Captured when discussing early engagement over NDA business case but nothing relating to underpinning plans

POSITIVE COMMENTS

1) Well structured, logical format Captured2) Language easy to understand Captured3) About the right size which makes

it easier to digestNot captured in note

4) Good layout and use of imagery Captured

Appendix 6

Feedback from Enablers Working Group to the NDA’s draft Business Plan

Page and section of business plan

Enablers working group response

Pg 12/13 – What we do Insufficient information about R&D, Skills and Socio-economics in plans presented later in the document.

Little or nothing quantitative on critical enablers in the plan

Positive that NDA is working with nuclear new build in terms of socio economics

Pg 14/15 – Look ahead This is a 3 year look ahead with two major closures, there is no indication of NDA’s intent on workforce, skills, jobs etc. following 2018/20 when Thorp/Magnox close.

Pg 16/17 – 20 year priorities.

Vitrification lines/Hales in POCO in 2022 – is this not too early in terms of strategic assets for the site?

High active wastes – preparatory studies – (when, where, what)

Higher activity wastes (inc RWM) – this is confusing and seems to be outdated. This is what the RWM needs to do.

Question – What are sites doing (by when) to ensure HLW activity wastes are disposed of?

What is RWM doing to progress GDF and what is the contingency we believe the 2040 availability is unachievable.

Pg 18 – Funding Planned income and expenditure summary 2017/18 – NDA has done well – two thirds of the expenditure spent in Sellafield areas.

Summary of NDA funding (18/19 onwards) –There is no breakdown of who gets what – need to ensure Sellafield is a priority

Pg 20 – Our funding 2017/18 breakdown of non-site expenditure – disappointing that there is a reduction in spend for socio-economics and R&D – need to see an increase

Pg 22 - Sellafield Key areas cover most important strategic operational objectives.

General observation that most of the activities begin with `continue’ far too qualitative, how can we as a taxpayer

measure how NDA have done – We can see progress but not compare it against a declared intent

What are the key tactical targets NDA is setting for Sellafield Ltd – (not enough detail) – tactical deliverables should be based on what Government has set the NDA. Would like to see at least one (preferably 2-3) quantified key tactical milestones for each key activities. What is NDA being held to account on and what is Sellafield Ltd being held to account on?

Please indicate what key strategic or tactical decisions the NDA require to take over the 3 year period in order to secure the 20 year look ahead.

Pu is still under government review however, plutonium arisings still occur from reprocessing and stored in old Pu stores in sep area, their products will be transferred into same or purpose built stores – question – how do we know it will be safe long enough prior to long term storage. What is taking place to ensure decision can be made early enough and that stakeholders have information early enough to influence the decision? – research and development needs to be funded to address this

Pg 24 – key activities The majority of things WCSSG raised in Strategy III are covered however there are gaps – ie: transport strategy

Pg 38 – non site summaries

Pleased to see cyber security is included

Nothing on socio-economics a serious omission given Magnox and Thorp closure

Pg 40 – Radioactive Waste Management

NDA radioactive waste management strategy (for the NDA estate) does not include `disposal’

Government haven’t tasked NDA with writing a national waste strategy – what is plan B for GDF?

No direct engagement with RWM – Enablers group need to develop a relationship

Pg 42 – NDA properties Ltd The paragraph has been poorly written, with no mention of the community or maximising public value of the assets – transfer to local authorities may be a better option

wcssg.co.ukwcssg.co.uk/.../01/...draft-business-plan-2017.docx · web viewthe plan addresses...

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