Strategic Nuclear and Energy Board 300118 Nuclear Decommissioning

Strategic Nuclear and Energy Board 300118

Nuclear Decommissioning Authority (NDA) - Draft Business Plan 2018 to 2021 Consultation

LEAD OFFICER: Pat Graham REPORT AUTHOR: Steve Smith

Summary and Recommendation: This report informs Members of the launch of the Nuclear Decommissioning Authority (NDA) - Draft Business Plan 2018 to 2021 Consultation. Representatives of the NDA will be attending the meeting to provide a short presentation on the priorities within this Business Plan.

Recommendation: 1. Members are requested to note the information contained in the document and highlight any views that they would like to forward to the NDA.

2. Members authorise the Managing Director, in consultation with the Chair of the Board, to agree the Council’s response.

1. Introduction & Background

1.1 Based on the third edition of the NDA’s Strategy, published in April 2016, the Draft Business Plan sets out key activities and expected progress for all 17 of the NDA’s nuclear sites over the next 3 years.

1.2 Included is a 20-year overview of forthcoming activities across all of the UK’s earliest nuclear sites.

1.3 The NDA core objective is to decommission these sites safely, securely, cost-effectively and in a manner that protects people and the environment.

1.4 The total planned expenditure for the financial year 2018/2019, is £3.15 billion, of which £2.27 billion will be funded by government and £0.88 billion by income from commercial operations.

2. The Consultation

2.1 The consultation runs until 4 February 2018.

2.2 The NDA will consider responses it receives to the consultation, and outputs from any NDA events, and revise the Draft Business Plan as appropriate.

2.3 Subject to approval by the UK and Scottish Governments, the NDA will publish the final version of this document in late March 2018.

2.4 The NDA - Draft Business Plan 2018 to 2021 can be viewed at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/671522/N DA_Draft_Business_Plan_2018_to_2021.pdf. A hard copy is also available for Members as part of this agenda pack. 1 3. Priorities and Key Issues

The NDA has identified a number of key milestones for the next 3 years across the estate, but of specific relevance to Copeland Borough are:

i. Complete THORP reprocessing 2018 Sellafield’s Thermal Oxide Reprocessing Plant (THORP) takes spent nuclear fuel from EDF Energy’s operational power stations and from foreign customers. The closure of THORP in 2018 remains on track. It will avoid the expense of replacing many of the plants that support its operation and allow Sellafield to focus on the primary task of decommissioning and remediation. The end of reprocessing operations in THORP provides a clear transition point for Sellafield. The site will move from commercial operations to decommissioning and continued management of spent fuel and waste.

ii. All Magnox reactors defueled and fuel transferred by 2019 Of the 11 sites across the NDA estate that have Magnox reactors, only 2 have yet to complete defueling: Wylfa in Wales will complete in 2018; Calder Hall on Sellafield site is scheduled to complete in 2019. By 2018 the radiological hazard on all Magnox sites across the UK will have been reduced by 99%. These sites will prepare to enter a period of quiescence known as the Care and Maintenance phase.

iii. Magnox reprocessing complete by end of 2020 Closure of the Magnox Reprocessing Plant at Sellafield is based on the latest Magnox Operating Programme and subject to the completion of defueling and the performance of ageing facilities that were built many decades ago. As a result of completing reprocessing, a series of products will be suitable for interim storage pending disposal or reuse. The conclusion of reprocessing also benefits the environment and complies with the UK Strategy for Radioactive Discharges.

iv. Retrievals from the high hazard facilities - Pile Fuel Cladding Silo and Magnox Swarf Storage Silos by 2020-2021 The Pile Fuel Cladding Silo is one of the oldest facilities at Sellafield. Retrieval of waste from the Pile Fuel Cladding Silo at Sellafield is scheduled to start 2 years earlier than forecast. A simplified, ground-breaking approach also reduces the cost of this work by almost £250 million.

v. Low Level Waste Repository – PCM dealt with by 2019 A series of concrete bunkers that once stored Plutonium Contaminated Materials (PCM) look set to be demolished at least 4 years earlier than expected - and for £30 million less than expected. Located at the Low Level Waste Repository near Drigg, Cumbria, the bunkers were known as magazines and stored PCM generated from operations at Sellafield in the 1950s-1960s.

4. Summary of Funding

i. Funding framework The NDA is publicly funded through the Department for Business, Energy and Industrial Strategy (BEIS), and total planned expenditure is voted upon annually by Parliament.

Revenue generated through the commercial activities of the NDA reduce the level of public funding required from Government. 2 ii. Commercial income NDA aim to maximise revenue from existing assets and operations to help fund decommissioning and clean-up, in order to reduce the level of public funding required to meet the scope of plans and delivery of the NDA mission. The commercial operations of the NDA are primarily spent fuel and nuclear materials management with additional opportunities identified in providing transportation services. NDA have stated in the plan that they “will pursue all commercial opportunities using existing assets, operations and people where it does not materially impact on core mission or increase liabilities”. This is seen as a departure from previous arrangements. iii. Planned income and expenditure in 2018/2019 This Business Plan sets out our anticipated income and expenditure for 2018/2019 as agreed with HM Treasury and BEIS. The total planned expenditure for 2018/2019 is £3.146 billion, of which £2.269 billion will be funded by UK Government and £0.877 billion by income from commercial operations. Planned expenditure on site programmes will be £2.967 billion, while non-sit expenditure is expected to be £0.179 billion. This non-site expenditure includes skills development, socio-economic, research and development (R&D), insurance and pension costs, fees to businesses, implementing geological disposal and NDA operating costs as detailed on page 22 of the draft document. iv. Planned Income and Expenditure Summary 2018/19

% of 2018/19 expenditure on Sellafield site is 64%.

3 5. Key Site Milestones & Activities

i. Sellafield Current Key Milestones  2018 - Completion of THORP reprocessing  2019 - Implement and embed the long-term partnership supply chain in Major Projects (Programme and Project Partner - PPP)  2020 - Begin retrievals from the Pile Fuel Cladding Silo and Magnox Swarf Storage Silos  2020 - Completion of Magnox reprocessing including defueling of Calder Hall Key Activities  Continue the safe and secure storage of plutonium in line with UK policy. 2018/21  Continue to receive and securely store special nuclear materials from Dounreay. 2018/21  Continue the programmes to receive and treat waste materials from Harwell and AWE Aldermaston. 2018/21  Continue with improvements to the site utilities infrastructure. 2018/21

ii. LLWR Current Key Milestones  2019 - PCM decommissioning complete.  2019 - Security programme complete.  2024 - Type B programme complete.  2025 - Final capping of Vault 8.  2080 - Final site clearance achieved. Key Activities  Work with the NDA to support innovation in approaches to waste management. 2018/21  Consideration of options to further optimise operations at the LLWR. 2018/21

6. Concluding comments

Members are asked to highlight any views that they would like to forward to the NDA in the consultation response. To assist Members and to provide context attached as Appendix A is a copy of the Council’s response to the draft NDA Strategy 3 from Jan 2016.

4 Appendix A Response to the consultation on the Nuclear Decommissioning Authority (NDA) Strategy III.

1. Introduction

1.1 Copeland Borough Council welcomes the opportunity to review and formally comment on the NDA’s draft Strategy III. This response has been developed through a range of Member workshops held in July and November 2015 and has considered both the draft strategy document published in September for engagement purposes and the latest draft published on 5th January. The Council recognises the significance of the work of the NDA to communities within our Borough due to the presence principally of the Sellafield site and the role that the site is playing in the national nuclear decommissioning agenda. The Council recognises the environmental risks associated with the continuing role of the Sellafield site. This risk will increase as the Sellafield site continues to receive spent fuel and waste transferred from other sites around the UK as they move through the decommissioning process. The Council continues to take the view that the removal of the intolerable risk at Sellafield must continue to be a national priority.

1.2 The Council welcomes the efforts made by the NDA to engage with the authority and its Members to help the Council to understand the nature of the NDA’s task across the UK and its strategy going forward. The Council would encourage the NDA to maintain this level of dialogue and engagement as the strategy develops and its implementation progresses recognising the national role that Copeland communities play in hosting the Sellafield site and related nationally significant nuclear-related facilities.

2. Generic Comments

2.1 A number of our Members commented that the initial draft for engagement provided in September 2015 was overly complex and difficult to digest with the subsequent risk that the efforts to draw comments and engagement from stakeholders may be undermined. In the revised version it is pleasing that the language and layout has been enhanced which should encourage stakeholders to respond. In general terms, the Strategy addresses the subject matters and areas expected, and where this isn’t the case and where the Council has specific comments to make these are detailed below in the following sections.

2.2 The Council has developed a ‘Growth Strategy’ for the Borough which is firmly based around the development of new nuclear-related energy production (focused around proposals by NuGeneration Ltd at the Moorside site) and maximising the economic development

5 opportunities from the specialist decommissioning skills and expertise developed through over 60 years of activity on the Sellafield site and more recent facilities of national significance in the locality including the National Nuclear Laboratory (NNL) and the Low Level Waste Repository (LLWR). The Council believes that this approach aligns with the UK Governments strategies for energy security and for the nuclear sector. The national Nuclear Industrial Strategy ‘sets out shared commitments with industry. It takes a long-term approach to the opportunities for economic growth and job creation from the nuclear industry:

• new build • waste management and decommissioning • operations and maintenance in the domestic and global markets

Developing opportunities like these will enable nuclear power to contribute to the UK’s energy mix and security of supply and help ensure the UK nuclear industry is able to realise its commercial ambitions.’

2.3 In addition the Council is a founder member of the ‘Centre for Nuclear Excellence (CoNE)’. The Centre of Nuclear Excellence is a Cumbrian partnership of public and private organisations which aims to maximise the benefit of the region’s nuclear capability and expertise for the local economy and UK as a whole.

2.4 Both the Councils own Growth Strategy and the CoNE vision and strategy are aligned with the strategic priorities of the Cumbria Local Enterprise Partnerships (LEP) Strategic Economic Plan and the vision and aspirations of the Government-led initiative around the concept of the Northern Powerhouse. In addition in April 2015 the Council agreed and adopted a set of nuclear related position statements which will be used to generate relevant Council policies and strategies and to generate comments on other agencies strategies including the NDA Strategy III.

The CoNE aspirations are currently centred on three transformational projects;

1. The decommissioning of the Sellafield site 2. The development of the new nuclear power station at Moorside 3. The development of the successor submarine fleet at Barrow.

2.5 However the Council and CoNE partners recognise the significant opportunities that are potentially offered by new nuclear missions including Small Modular Reactors (SMRs), national spent fuel stores and future Mixed Oxide (MOX) fuel plants through the re-use of the UK civil

6 separated plutonium stocks. The Council is therefore keen to see reference to the development of new nuclear missions within the Strategy and to understand the role of the NDA in taking these missions forward.

2.6 The Council recognises that the Sellafield site operates in the national interest which will continue and potentially expand for some considerable time into the future. While parts of the site are decommissioning, to reduce risk and hazard, other areas will expand and have a long- term future and potential new missions.

2.7 It is against this national, regional and local strategic context that the Councils comments on the draft NDA Strategy III document have been developed. The Council expects that the final NDA Strategy III will provide strategic support to the Councils economic growth aspirations.

2.8 In view of the delay to the commencement of the consultation process for the draft Strategy caused by the implications of the Governments Comprehensive Spending Review (CSR) the Strategy should include recognition of the limitations of funding availability and how such circumstances will be managed across the estate, including the potential impact on delivering the mission. Summary of Council Generic Comments

 The Council are keen to maximise the economic growth opportunities from current and new nuclear missions and to understand the role of the NDA in supporting the national and local growth agenda

3. Overarching strategy and role of NDA

3.1 In the light of changes proposed for the management of the Sellafield site and the emerging proposals for the development of the Moorside site as a new nuclear power station the Council believes that there is a need to review governance arrangements for the nuclear industry. In particular the Councils view is that the current remit of the NDA is restricting its ability to play a full role in the local growth agenda discussion and therefore limits the scope of the strategy to deal with issues outside of the decommissioning agenda. This in turn limits the ability of the NDA to contribute resources into developing new missions aligned to the national and local growth agenda including supply chain development. The role of NDA was established under the 2004 Act for a ‘sunset industry’ which is now no longer the case. The Councils view is that this role focussed on progressing clean-up and decommissioning has been superseded by industry changes, is out of date and actually restricts the NDAs ability to fulfil their socio- economic obligations and objectives under the Act. It also restrict the NDAs ability to make a substantial contribution to the national growth agenda associated with the nuclear renaissance including the substantial opportunities around maximising the commercial opportunities for the UK from our decommissioning expertise.

7 3.2 In addition the nuclear renaissance provides the rationale for continued investment in socio-economics in Cumbria to safeguard and protect the local skill base in the national interest and to re-establish the UK as a world leader in decommissioning capability through maintaining and enhancing the national skill base in this sector. The Council believes that it is in the best interests of the UK PLC that the UK maintains world class expertise and capability in decommissioning to achieve the long term mission and deal with the full range of unique issues.

3.3 Significantly the Council takes the view that the future role of the NDA role should include the scope to develop new nuclear missions utilising its expertise in decommissioning to contribute to the national nuclear renaissance.

3.4 In this respect the Council believes that mission success across the NDA estate but particularly at the Sellafield site has a great potential impact on nuclear reputation and credibility nationally, and therefore will support or undermine future nuclear generation. The Council view therefore is that the priority for investment in the strategy and the key objective for the strategy must be to deliver the investment needed to increase national confidence in the competence and capability at Sellafield. The Council believes that this position is supported by the NDAs approach to the prioritisation of risk as contained within the draft Strategy.

3.5 Our Members shared concerns that public and stakeholder engagement needed to be reviewed in the light of the new management model for the Sellafield site and the proposed additional activities in the locality around nuclear power generation. Whilst the Council recognise the current positive role that the WCSSG plays there is a view that the context for the Group has changed and needs to better reflect the local growth and socio-economic agenda and greater emphasis should be placed on disseminating the views and outcomes of the SSG deliberations across the communities of Copeland.

3.6 The Council believes that the strategy should clearly identify how the new management model for the Sellafield site will affect the detailed outcomes and proposals contained within the Sellafield Lifetime Plan particularly in relation to employment needs going forward. However it is not clear in the Strategy what the residual role of the NDA will be in relation to the Sellafield site and how the strategic overview of progress at the site will be maintained and monitored. The Council will expect these issues to be articulated in the next Sellafield Business Plan.

3.7 The Council sees significant opportunities to develop approaches to new nuclear missions in West Cumbria and therefore maximise the expertise locally for the benefit of the UK as a whole. To achieve this there is a need for an integrated approach to the nuclear sector – from energy production through new build and decommissioning/storage. New build success is inevitably dependant on decommissioning skills – and the expertise and skills on offer locally is part of the local ‘offer’ to UK Government from Copeland and its communities. Without such a 8 joined-up approach there is potential for tensions between a national strategy for decommissioning and a site at Sellafield with new opportunities and missions. The Council’s view is that the Strategy should reference the national governance arrangements for the nuclear sector as context for the development of the content of the Strategy and would specifically request that the interface between UK Government departments and the NDA are included.

3.8 The Council is keen to ensure that the Strategy recognises the significant linkages between the decommissioning challenges at the Sellafield site and the development of a new nuclear power station on the adjoining Moorside site. Issues such as transport infrastructure and emergency planning require a coordinated response from the variety of agencies involved and under the current arrangements the Council is concerned that there is the potential that the cumulative impacts of both sites will not be fully understood and planned for. Summary of Council view on overarching strategy and role of NDA

 The Council seeks clarification on the role of the NDA in relation to the wider governance of the nuclear sector at a national level to ensure that collectively we can maximise the economic opportunities from the ‘nuclear renaissance’ and the commercial opportunities from decommissioning.  The Council supports the Strategy III prioritisation of the Sellafield site for resource in view of the environmental risk but also in recognition of the fact that mission success at Sellafield is crucial to the UK nuclear reputation and potential international decommissioning business opportunities.

4. Site Decommissioning and Remediation

4.1 The Council supports the suggestion within the strategy that the priority should be to deal with the highest risks across the NDA estate first and such risks should be the priority for funding. Dealing with high hazard reduction and community safety is of paramount importance and the focus for effort and resource should therefore be the Sellafield site. Similarly the Council supports the use of the ‘Value Framework’ to determine priorities for action and the subsequent conclusion that intolerable risks require priority attention. The Council points out though that the success of the clean-up or decommissioning of a site elsewhere in the country for the most part involves the movement of materials and therefore the resultant transfer of risk to the Sellafield site.

4.2 In this respect the Council is concerned about the ‘ad-hoc’ nature of the development of the Sellafield site particularly in relation to the incremental movement of materials from other parts of the NDA estate (and therefore the incremental increase of risk) and as such the Strategy fails to recognise and give recognition to the special ‘national’ status that the site (and the local community) has. Whilst the technical arguments may suggest that the site is the most appropriate location for the treatment and/or storage of those materials and for the most part the local community has accepted this position, no formal decision has been taken locally regarding this status. The Council therefore urge the NDA to include within the strategy 9 acknowledgement of the national status of the role of the Sellafield site and include for the development of a long term plan for the movement of materials to the site and an associated coordinated community benefits package within forthcoming business plans.

4.3 The Council view is that for decommissioning and remediation a long term programme is needed and technical expertise is going to be essential to the successful delivery of that programme. It is important then to ensure that the development and restructuring of the current workforce is carried out against the requirements of this programme so as to maintain existing skills and expertise and develop them further as the programme progresses.

4.4 The Council welcomes the outcome of the Governments Comprehensive Spending Review (CSR) which supports the continued commitment to the decommissioning and removal of the intolerable risks on the Sellafield site and in this regard seeks assurance through the Strategy to the commitment from the NDA and Government to a pro-active dialogue with the Copeland community.

Summary of Council view on Site Decommissioning and Remediation

 The Council is concerned at the relative incremental nature of the movement of waste materials from other parts of the NDA estate which transfers risk to the Sellafield site and whilst the technical arguments may suggest that the site is the most appropriate to deal with these wastes there is no formal local decision that the community is willing to accept this position nor is there recognition that the Sellafield site is acting in the national interest.

5. Spent fuels

5.1 The Council has a number of issues concerning spent fuel management. The Council notes that the international view is that spent fuel is regularly seen as an asset. In this regard the Council view is that the strategy should reference the application of the principle of reprocessing spent fuel before any consideration of long term storage or disposal.

5.2 The Council shares the view of the WCSSG that the timetable for ceasing reprocessing is ‘driven more by a stated schedule than by need’. The Council supports the suggestion by the WCSSG that reprocessing is a better option than geological disposal for the treatment and management of spent fuel. The Council is equally concerned that additional compelling evidence is needed to prove the integrity of the approach currently suggested. In addition the Council suggests that the Strategy needs to be explicit about how, beyond the end of reprocessing, spent fuel will be managed.

10 5.3 The Council is naturally concerned about the economic impact of the run-down of reprocessing. The Council takes the view that there is no clear policy for re-processing going forward. Whilst currently there is a limited national/international market for re-processing there is a view that this will change in the future as more countries (including the UK!) are choosing a nuclear option for the generation of electricity and therefore creating spent fuels. The Council would like to see the strategy clearly spell out how the NDA will proactively review the opportunities for re-processing with timescales for delivery.

5.4 The Council view is that whilst Sellafield is the best place to process, manage and store spent fuel the level of risk to the Copeland community warrants consideration of an appropriate community benefits package. It is the community that is accepting the waste and should therefore be appropriately compensated. The site has the expertise in both managing and storing spent fuel safely and securely. The Council is also of the view that it may be beneficial for the UK to have a centralised spent fuel store and from a safety and security perspective the obvious location for this would be at Sellafield.

5.5 The Council notes that the Strategy refers to placing the remaining and future arisings of spent fuel into interim storage pending a future decision to declare them for disposal in a geological disposal facility (GDF). Noting previous comments about viewing spent fuel as an asset the Council is not supportive of this approach and asks would spent fuels be identified as retrievable commodity if included in a GDF inventory? Also if this approach is accepted the Council would be concerned about the impact on the scale of the inventory for a GDF resulting from the inclusion of spent fuel. Summary of Council view on Spent Fuels

 The Council supports the international view that spent fuel is an asset and as such the UK should consider reprocessing rather than disposal and would like to see the strategy clearly spell out how the NDA will proactively review the opportunities for reprocessing with timescales for delivery.

6. Nuclear Materials

6.1 The Council takes the view that the Strategy shows little on future plans for managing and storing exotic material. The Strategy requires a definitive statement on this and also the future plans for residual fuels, such as those from prototype reactors. It is also not clear how the Strategy will address the ownership and treatment of MoD waste (spent fuel) on the Sellafield site. Whilst this is currently outside of the NDA’s scope it does highlight another example of where a more joined-up approach across the industry is required.

6.2 The Council agrees with the strategy that the priority is to deal with the future of the plutonium stocks but takes the view that Plutonium (as a useable or re-usable commodity) should not be included in the inventory for a future GDF. That said the strategy lacks clarity on 11 how the NDA plans to manage plutonium storage in the interim. This is the single biggest factor in the Sellafield site’s risk profile, and a major factor in security costs. Despite this Strategy III is less explicit about the use of plutonium than previously, and it makes no mention of the taxpayer cost of holding this useable commodity. The Council recognises that the future treatment of the plutonium stocks requires a Government-wide decision and would urge that such a decision is made swiftly. Our preference would be to re-use it as this would reduce the need for safe and secure storage.

6.3 The Council notes that the Strategy is silent on the issue of spent fuel produced by new- build generators (suggesting that it outside of the remit of the NDA?) and questions how will this be dealt with in the long term post on-site storage.

6.4 Copeland Members have also raised the question of what would happen to Dounreay waste in the event of the future independence for Scotland. Councillors have also requested that the strategy needs to be clearer on the future of internationally-owned plutonium and whether there is still an intention to return it to the country of origin. Summary of Council view on Nuclear Materials

 The Council agrees with the strategy that the priority is to deal with the future of the plutonium stocks but the strategy lacks clarity on how the NDA plans to manage plutonium storage in the interim and is less explicit about the use of plutonium than previous strategies  The Council recognises that the future treatment of the plutonium stocks requires a Government-wide decision and would urge that such a decision is made swiftly. Our preference would be to re-use it as this would reduce the need for safe and secure storage.

7. Integrated Waste Management

7.1 The Council is fully supportive of the need for the development of an integrated waste management strategy and that such a strategy should have the utilisation of the waste hierarchy at its core. Additionally the Council supports the notion of further investigation of the opportunities to share waste management infrastructure across the estate and suggests that in the interests of economy/efficiency West Cumbria will be at the heart of the implementation plans for any future investment as a result of such investigations. These plans would build on the expertise currently within the West Cumbrian working population around decommissioning and waste management and doing this in one place would produce spin-off economic benefits for the UK.

7.2 The Council believes that the strategy should clarify exactly what is a waste or an asset, particularly in relation to the stocks of plutonium and uranium held at Sellafield. The Council

12 would advocate reuse rather than disposal wherever possible – particularly for plutonium, which the NDA has suggested could be put into a GDF – and has a similar view for spent fuels.

7.3 The Council believes that there is a need for a clear strategy on high/intermediate level wastes. The strategy currently assumes that for higher activity wastes a GDF will be provided within decades. Progress on identifying a suitable site in the UK has been slow and the Council shares the view that in the meantime the strategy should include for the provision of conditioned waste forms and appropriate storage facilities for the foreseeable future. The Council would also reiterate that the design for the GDF should include the scope for retrievability and that reprocessing should be considered as a solution rather than direct disposal of spent fuel.

7.4 The waste management sector for other waste streams in the UK is ripe for the development of new processes and techniques for dealing with wastes but the strategy gives limited profile to R and D, and the nature of the on-going work at Sellafield suggests that additional investment in R and D is going to be important. Additionally the Council would like to see better coordination between licensed disposal sites in the locality to ensure that we maximise the potential for recycling and re-use of wastes where appropriate, reducing cost and environmental impact and promoting economic opportunities from waste treatment activities.

7.5 The Council has already expressed the view that the role of the NDA should be re- assessed as a consequence of changes within the sector. This is especially relevant in relation to land management. The strategy should allow for acquisition and disposal of land by the NDA for other uses associated with the delivery of the decommissioning mission although not necessarily core to the mission itself. This will assist the long term UK wide mission, the UK and local growth agenda and allow the NDA to more fully fulfil its socio-economic objectives. The Council expects the strategy to allow for the development of credible end-states for specific sites with the engagement of local stakeholders, which translates into a clear strategy for land management locally supporting the delivery of the mission but also supporting the opportunities for consideration of new missions and associated economic development opportunities as part of the NDAs socio-economic contribution. Whilst the Council recognises that the strategy should make reference to the fact that the NDA should only retain land required to complete the mission there is an expectation that land clearly surplus to requirements will only be considered for disposal once an assessment has been completed with the engagement of local stakeholders into the potential for the land to contribute to the local growth agenda. Summary of Council view on Integrated Waste Management

 The Council is fully supportive of the need for the development of an integrated waste management strategy and supports the notion of further investigation of the opportunities to share waste management infrastructure across the estate.  The Council believes that there is a need for a clear strategy on high/intermediate level wastes and that in view of the slow progress on identifying a site for a GDF that in the

13 meantime the strategy should include for the provision of conditioned waste forms and appropriate storage facilities for the foreseeable future.  The Council would like to see better coordination between licensed disposal sites in the locality to ensure that we maximise the potential for recycling and re-use.  In relation to land management the Council view is that the strategy should allow for acquisition and disposal of land by the NDA for other uses associated with the delivery of the decommissioning mission although not necessarily core to the mission itself but which contribute to the national and local growth agenda.

8. Critical enablers

The Council has a number of comments relating to some of the critical enabler topics.

8.1 In relation to transport and logistics the strategy needs to reflect the unique circumstances in West Cumbria and the national significance of the current and future facilities both in terms of decommissioning, waste management and new nuclear. The Council view is that the strategy in its current form lacks the clarity and detail of approach in relation to the movement of people and goods and could undermine the NDAs ability to deliver its mission. The Council expects the strategy to spell out how the NDA will engage with others including the Cumbria LEP and local authorities to ensure that the infrastructure implications of future decommissioning and waste management plans are considered alongside current and planned developments in other sectors including nuclear new build and designed and funded accordingly. In addition to moving people to and from sites for work the strategy needs to also consider how people would be moved as a result of unpredictable changes such as extreme weather conditions.

8.2 The Council therefore expects Strategy III to support the socio-economic argument for the need to develop and fund an appropriate integrated transport strategy for Cumbria which meets the long term needs of the continuity of the national role for the Sellafield site and allows the local area to maximise the opportunities from decommissioning, waste management, nuclear new build and other major developments aimed at diversifying the local economy. The Council takes the view that travelling to work is a major risk for employees and would seek through the strategy to ensure that all SLCs are obliged to develop and agree travel plans to ensure the safe movement of employees to their workplace.

8.3 In terms of people and the skills agenda the Council expects the strategy to include a proposal for maintaining future competence and succession within the workforce to minimise the risk of failing to deliver the mission. In this regard the Council takes the view that the scope and scale of the skills and expertise contained within the current Sellafield workforce (and associated supply chain) is a ‘national asset’ and is it is in the national interest to build on this skill base. The Council is aware of the national scope and scale of the skills challenges for the nuclear sector and believes that through the recognition and support to the development of the 14 Centre of Nuclear Excellence (CoNE) and the future of the nuclear activity in Cumbria there is real opportunity to expand the skills base for the benefit of the nuclear sector across the whole of the UK.

8.4 The Council expects the strategy to be clear about the need and mechanism for identifying the skills required for the continued delivery of the decommissioning mission at Sellafield and the route by which new skill needs will be delivered, including the role of stakeholders and agencies and training providers in that process. The Council makes no apology that its aspirations are centred on maximising employment opportunities at Sellafield and its supply chain for Copeland residents. Through the socio-economic aspects of Strategy III the Council expects the NDA to clarify the means by which unskilled residents will be able to access employment opportunities through the range of decommissioning programmes particularly on the Sellafield site. In recognition of the long term nature of the mission the strategy should include reference to the need to ensure the transferability of skills within current workforce to new nuclear missions. The strategy needs to identify the role of the NDA in raising the profile of the nuclear industry generally and decommissioning specifically as a chosen career route and encourage STEM take up in schools.

8.5 The Council recognises the inter-generational nature of the nuclear decommissioning agenda and so there is a need for the Strategy to consider mechanisms for engaging young people in both consultation and for taking an interest in a future career in the sector. The strategy needs clear planning for future capability and skill requirements, and the development/upskilling of the local workforce (directly and via enough well-equipped trainers) to build capacity and ensure sustainable employment for communities across Cumbria.

8.6 In terms of socio-economics the Council wish to see future development in the supply chain, so that local suppliers have the capability to meet future procurement needs. This must be cohesive with workforce plans so that the SLC and the supply chain are not competing in the same talent pool. In the context of the national growth agenda and the National Nuclear Strategy the Council is concerned that the national supply chain in its current state is insufficient in terms of both capacity and capability to deliver the country’s future needs around decommissioning and nuclear power generation through the nuclear new build programme. The Council expects the NDA to use its relationship with Government (including DECC and BIS) and the nuclear sector to ensure that the resource required to develop the supply chain to maximise the opportunities for UK businesses is in place and the programmes required to ensure that companies are ‘fit for nuclear’ are available and delivered in a coordinated manner.

8.7 The Strategy needs to recognise the implications for infrastructure and community services if Copeland is to continue to operate at the core of UK nuclear functions – especially in view of the likely need to attract additional skilled people to locate here. This is especially the case in relation to local essential services such as health and the impact of emergency planning on local infrastructure.

15 8.8 The Council expects the strategy to clearly articulate the expectations that the Government has for the nuclear decommissioning sector/SLCs to deliver ‘a Living Wage’ and to eradicate the use of zero-hour contracts.

8.9 The Strategy should identify the role that the nuclear decommissioning sector could play in the national growth agenda through ‘international market exploitation.’ This could be a direct ‘return on investment’ for Government expenditure. The fear is that this function which is not in the current remit of the NDA is allowing opportunities to go elsewhere. In addition the strategy should be clear on the role of the NDA in commercialising decommissioning skills for the benefit of the UK growth agenda generally. Summary of Council view on Critical Enablers

 The Council expects the strategy to spell out how the NDA will engage with others including the Cumbria LEP and local authorities to ensure that the infrastructure implications of future decommissioning and waste management plans are considered alongside current and planned developments in other sectors including nuclear new build and designed and funded accordingly.  The Council therefore expects Strategy III to support the socio-economic argument for the need to develop and fund an appropriate integrated transport strategy for Cumbria which allows the local area to maximise the opportunities from existing, planned and future nuclear missions.  The Council expects the strategy to be clear about the need and mechanism for identifying the skills required for the continued delivery of the decommissioning mission at Sellafield (recognizing that the skills of the current Sellafield workforce should be seen as a national asset) and the route by which new skill needs will be delivered, including the role of stakeholders and agencies and training providers in that process.  The Council view is that the strategy should clearly spell out the need to engage with young people and to promote career opportunities within the wider nuclear sector  The Council expects the NDA to use its relationship with Government (including DECC and BIS) and the nuclear sector to ensure that the resource required to develop the supply chain to maximise the opportunities for UK businesses is in place and the programmes required to ensure that companies are ‘fit for nuclear’ are available and delivered in a coordinated manner.  The Council expects the strategy to clearly articulate the expectations that the Government has for the nuclear decommissioning sector/SLCs to deliver ‘a Living Wage’ and to eradicate the use of zero-hour contracts.  The Strategy should identify the role that the nuclear decommissioning sector could play in the national growth agenda through ‘international market exploitation.’