NDA Draft Business Plan
Summary of submissions to the public consultation February 2008
This report is a summary of the online responses only and not those received by post, fax or email.
Ref CD12
Document Details: Published.
The Convenor The Convenor is an independent third party that engages stakeholders in the NDA’s business of cleaning up the nuclear legacy. The Convenor is a partnership between two organisations: 3KQ focuses on consultation, dialogue and conflict management, having particular strengths in designing, organising and facilitating meetings and workshops Dialogue by Design focuses on using new technologies to engage stakeholders, for example via consultation over the internet
Contact:
Telephone 020 8683 6833 Convenor for NDA Stakeholder Engagement 7th Floor, Ambassador House, Brigstock Road Thornton Heath, Surrey, CR7 7JG sarahg@dialoguebydesign.com rhuari@3kq.co.uk
Contents List
1.0 2.0 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 3.9 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 Introduction ........................................................................................................................ 2 Overview ............................................................................................................................. 3 Objectives: 2008/9-2010/11 .......................................................................................... 4 Encourage the highest standards in health, safety, security & environmental Deliver hazard reduction .............................................................................................. 4 Progress decommissioning & clean up ...................................................................... 5 Maximise commercial value......................................................................................... 6 Manage radioactive waste safely................................................................................ 7 Determine the scope of the liabilities ........................................................................ 7 Provide socio-economic support and development ................................................ 8 Deliver investment in skills, research & development and supply chain Enabling objectives ....................................................................................................... 9 Sellafield Limited ............................................................................................................. 10 Magnox North Limited .................................................................................................... 10 Magnox South Limited.................................................................................................... 11 Dounreay Site Restoration Limited .............................................................................. 12 Research Sites Restoration Limited ............................................................................. 12 Low Level Waste Repository Limited ........................................................................... 13 Springfields Fuels Limited .......................................................................................... 13 Subsidiary Companies ................................................................................................ 13 Any other comments?................................................................................................. 14
performance ............................................................................................................................... 4
development............................................................................................................................... 9
Appendix 1: List of participants ............................................................................................... 15
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DA Draft Business Plan: Summary of submissions, February 2008
1.0
Introduction
Background. The NDA's draft Business Plan for 2008/2011 outlines the key challenges and priorities for the NDA over this period. With a budget of £8.5 billion for the next three years this will be the largest amount of expenditure on the UK civil nuclear clean-up programme ever made and represents an increase of £671 million compared with the last three years. The draft Business Plan document was put out to formal public consultation for 12 weeks, from 7th November 2007 to 31st January 2008. This report is the summary of all consultation responses submitted online via the NDA's independent Convenor for Stakeholder Engagement, who managed the online consultation process. The reader will find it helpful to have a copy of the draft Business Plan to hand whilst reading this summary report. Invitees. Everyone on the NDA's stakeholder engagement database was invited to participate in the consultation. This included National Stakeholder Group (NSG) members and Site Stakeholder Group (SSG) members via their secretariats. The consultation was publicised on the NDA website and via the NDA email alert for anyone to participate, and people were encouraged to tell colleagues about it. Methods used. For the duration of the consultation people wanting to comment could either register and participate online and/or request a paper version be sent to them and return paper responses via a Freepost address. Participants. A total of 127 people participated. 180 people and organisations registered online, 77 of which went on to actually participate. A further 50 people and organisations participated via paper. A list of those who participated is in Appendix 1. Interpreting the Results. It is important to remember, when interpreting the results, that this is a qualitative consultation, not an opinion poll. Its primary purpose is to collect views and arguments. Care must be exercised therefore in attaching too much significance to the proportion of responses arguing one way or another. The grouping of comments under each section heading should not therefore be interpreted on a purely statistical basis. The groupings are useful indicators of where there is commonality. Taken in relation to each other, they help to clarify the range of issues and concerns identified by a multiplicity of stakeholders, and where general agreement or specific differences exist. The categorisation of responses is also necessarily simplistic given their complexity, so for this reason again it would be unwise to draw firm quantitative conclusions from them. All the detailed responses are available to view on the consultation website. This report is divided into three sections introduction; results and findings from the online and paper-based consultation; and next steps, and appendices The responses for each of the questions are also available online at www.ndabusiness.dialoguebydesign.net
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DA Draft Business Plan: Summary of submissions, February 2008
2.0
Overview
Q. Do you have any comments on the issues raised in this section? 59 people responded to this question. The great majority of comments revolved around the shift in the NDA’s priorities towards hazard reduction at Sellafield and Dounreay and the resulting impact on skills, jobs and the economic health for other sites. Some comments felt that these changes were being presented as a fait-acomplis rather than as a result of the consultation. There was also a sense from people who were concerned about the shift in priority and believed that the NDA would be better taking a few sites and completely decommissioning them as fast as possible, since this would show real action, help gain public trust and take these sites ‘off the NDA’s books’. Some participants also took the opportunity to make general comments such as the apparent change or broadening of the NDA's original remit, a sense that there needs to be a clear funding commitment for three years rather than funds potentially shifting during the three year period. A number of participants raised the need to communicate better with the general public and to demonstrate success in achieving the NDA's objectives.
Group Heading Challenge shift of priorities to high hazard sites Clarification needed Comments on the consultation process Concern about escalating costs Concern for loss of funding for specific sites Concern over apparent change in NDA remit Concern over competition approach Concerns about the accuracy of the document Consider the role of stakeholders General observations MOP issues More emphasis on new technology Need for clarity of funding for 3 years No comment Public communication and demonstration of success Reconciling social and economic effects Relationship between decommissioning and new build Repository issues Skills transfer / loss issues Support the overview approach
Number of comments 17 5 5 3 16 3 1 2 3 13 1 1 3 4 5 1 1 2 12 4
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DA Draft Business Plan: Summary of submissions, February 2008
3.0
3.1
Objectives: 2008/9-2010/11
Encourage the highest standards in health, safety, security & environmental performance
Q. Do you have any comments on this objective? 46 people responded to this question. The majority of comments agreed that HSSE performance is of utmost importance and that there could be no argument over this. A number of participants commented on targets, monitoring and performance and some had specific suggestions as to how this should be carried out in that targets should be realistic and that the NDA should liaise with the Site Licence Companies (SLCs) so that they are aware of audits and standards and can plan accordingly. There was concern expressed among some participants as to the socio-economic effects that are currently being felt particularly across the southern sites. Cuts in funding are leading to low morale and low commitment made worse due to the lack of consultation that has taken place. Group Heading Challenge the prioritisation Clarification needed Funding /cost concerns MOP issues No comment Reconciling social economic effects Refer to other question Related specific suggestion Role of regulators and other stakeholders Skills, research and development Support this section of the Business Plan Targets, monitoring and performance Number of comments 2 2 4 1 5 9 1 5 5 2 15 12
3.2
Deliver hazard reduction
Q. Do you have any comments on this objective? 41 people responded to this question. The majority of comments challenged the prioritisation process being used by the NDA. There was a view expressed that it would be better to focus on the clean-up at the lower hazard sites and concern was expressed as to when these sites would be able to recommence decommissioning: e.g. would they have to wait until Dounreay and Sellafield were at an equivalent level of hazard. Another view was that people would like to be convinced that the money going to Sellafield was being adequately controlled.
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Other comments made on this objective were relating to skills transfer issues. Concern was expressed that skills would be lost at the other sites due to the change in funding allocation. Group Heading Amendments to plan needed Apply to all sites Challenge the prioritisation Consider risk appraisal Funding concern Government responsibilities Issues around the hazard baseline Need for clarification Need to find final repository No comment Reconciling social economic effects Refer to other question Skills transfer issues Stakeholder involvement and communication Supply chain concerns Support this section of the Business Plan Number of comments 2 1 24 1 5 1 3 1 1 2 2 1 5 1 2 6
3.3
Progress decommissioning & clean up
Q. Do you have any comments on this objective? 49 people responded to this question. Most comments were along a similar line to the last section. Concern was expressed that the NDA seems to have taken a significant step away from its remit of decommissioning and clean up. Once again, concern was expressed that the lower hazard sites are going to be left indefinitely and that costs will rise due to this. Other comments were made specifically regarding an opportunity being lost at Harwell and Winfrith if decommissioning was not completed at these sites in the short term and again about the loss of skills that would follow in these areas. Group Heading Calculating hazard Challenge statements in the business plan Concern about changing priorities Concern over increased costs due to delay Concerns over graphite Extend Shared Services
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Number of comments 1 4 14 2 4 1
DA Draft Business Plan: Summary of submissions, February 2008
Focus on Bradwell Focus on Chapelcross Focus on Harwell / Winfrith Focus on Windscale Funding concern Involve stakeholders more NDA remit New build No comment OSPAR commitments Reconciling social economic effects Relationship between decommissioning and new build See previous comment Skills transfer / loss issues Specific comment/suggestion Support these objectives
1 1 9 1 1 1 1 1 2 4 1 1 1 7 4 4
3.4
Maximise commercial value
Q. Do you have any comments on this objective? 38 people responded to this question. Comments were divided on this objective in that some supported it and firmly believed that the assets should be used to generate as much income as possible, whilst others were concerned that commercial operations were diverting the NDA’s attention away from its core remit of decommissioning and that the NDA should not depend on commercial operations for its income. Group Heading Challenge the prioritisation Comment on Berkeley Comments on DRS Concern over competition schedule Funding concerns MOX issues Need for clarification No comment Operations versus decommissioning Opportunities for Harwell/Winfrith Opportunities for Springfield and Capenhurst Reconciling social economic effects Relationship between decommissioning and new build Resourcing issues
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Number of comments 2 1 1 1 2 1 2 3 7 2 1 1 1 1
DA Draft Business Plan: Summary of submissions, February 2008
Specific suggestion/comment Suggestions regarding new build Support these objectives
7 4 9
3.5
Manage radioactive waste safely
Q. Do you have any comments on this objective? 35 people responded to this question. Most comments received were generally supportive of this objective. Others expressed the view that a repository needs to be found and that they were pleased that an organisation had been identified to take this forward. However, some respondents felt that there could be a conflict of interest between the NDA’s remit of decommissioning and clean-up and its new role in implementing a geological disposal facility. Group Heading Challenge the prioritisation Concern over geological disposal facility Environment concerns Funding concern LLW Strategy More thought needed NDA & Governments role Need to find repository No comment Reconciling social economic effects Relationship between decommissioning and new build Site specific comment Stakeholder engagement comments Storage of ILW Suggestions regarding new build Support objectives Number of comments 2 4 2 2 1 1 2 8 2 1 1 3 3 4 1 7
3.6
Determine the scope of the liabilities
Q. Do you have any comments on this objective? 31 people responded to this question. Most comments received on this objective were views on projecting liabilities. Some expressed concern that plans were continually being updated and were then out of date again as soon as they were completed meaning that more time and resources are being taken up planning rather than doing the work.
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DA Draft Business Plan: Summary of submissions, February 2008
Group Heading Challenge the need for this objective Challenge the prioritisation Funding concern Need for clarification Need for clarity and transparency No comment Procurement process Reconciling social economic effects Support this objective Views on projecting liabilities
Number of comments 1 4 2 3 1 5 1 1 3 14
3.7
Provide socio-economic support and development
Q. Do you have any comments on this objective? 44 people responded to this question. The largest area of concern raised to this objective was that sites where funding is being cut were largely being ignored in terms of socio-economic support. Respondents felt that some areas are being concentrated on too much to the exclusion of others such as the Magnox south sites and Hunterston. Some respondents disagreed with making socio-economic support dependent on efficiency savings. A large number of responses though were also supportive of this objective. Group Heading Challenge the proposed spend Concern for other sites Concern over efficiency savings Concern over NDA commitment to this objective Funding concern versus investment return Is this NDA remit? More detail required Need to improve communications No comment Reconciling social economic effects Skills transfer / loss issues Specific suggestion/comment Support these objectives Number of comments 3 12 3 3 2 2 4 1 2 2 6 4 11
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DA Draft Business Plan: Summary of submissions, February 2008
3.8
Deliver investment in skills, research & development and supply chain development
Q. Do you have any comments on this objective? 36 people responded to this question. The responses to this objective were split between people supporting the NDA’s plans for initiatives such as the National Skills Academy for Nuclear and the Dalton Institute and others who expressed concern that, whilst it is a good thing that skills should be being developed, it is slightly ironic that the plan means there will be skills lost at the sites where funding is being cut. Group Heading Challenge focus on skills shortage Challenge the prioritisation Concern for specific sites Concern over focus on NW & Dounreay Funding concern Is this NDA remit? Loss of confidence in NDA Need for clarification No comment Reconciling social economic effects Skills transfer / loss issues Specific suggestion/comment Supply chain concerns Support these objectives Number of comments 2 1 3 3 1 1 1 4 3 1 12 6 1 9
3.9
Enabling objectives
Q. Do you have any comments on these objectives? 33 people responded to this question. 11 people who commented on this section challenged the competition approach, largely because they are not convinced this is the best way to drive cost efficiencies or because this is maybe at odds with the priority for health and safety. Group Heading Challenge NDA management costs Challenge the competition approach Challenge the prioritisation Comment on Winfrith Comments on budget Concern over privatisation Number of comments 3 11 1 1 1 1
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DA Draft Business Plan: Summary of submissions, February 2008
Funding concern General observations Need for clarification No comment Pre-conditioning of waste Reconciling social economic effects Specific issues Support these objectives Refer to other comments
2 1 2 4 1 1 5 5 1
4.0
Sellafield Limited
Q. Do you have any comments on the key activities and/or key focus for any of the sites managed by Sellafield Ltd? (Please state which site(s) you are referring to in your submission). 22 people responded to this section. Concern was expressed over the prioritisation of Sellafield over other sites. Whilst people recognised the need for hazard reduction work at Sellafield some did not think that this should be at the expense of other sites. There was also some concern expressed over the key site activities planned for Sellafield and whether these were the most appropriate. Group Heading Focus for Sellafield sites Loss of skills Loss of UKAEA name Magnox Operating Plan Need for clarification No comment Prioritisation of Sellafield over other sites See previous comment Support key activities Number of comments 1 1 1 3 3 5 5 1 3
5.0
Magnox North Limited
Q. Do you have any comments on the key activities and/or key focus for any of the sites managed by Magnox North Ltd? (Please state which site(s) you are referring to in your submission). 22 people responded to this section. There were a number of comments specific to sites, some concerns about funding, the Magnox Operating Plan and some queries about the data in this section.
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Group Heading Comments on Chapelcross Comments on Oldbury Error in plan Funding concerns Magnox Operating Plan Need for clarification No comment Separate Dounreay & Sellafield from other sites Skills, research and development Specific detailed suggestion
Number of comments 1 2 2 4 4 4 7 1 1 2
6.0
Magnox South Limited
Q. Do you have any comments on the key activities and/or key focus for any of the sites managed by Magnox South Ltd? (Please state which site(s) you are referring to in your submission). 24 people responded to this question. Concern was expressed over funding and prioritisation of work. Other comments received were either site specific or querying the key activities planned. Group Heading Comment on Site Stakeholder Group Comments on Berkeley Comments on Bradwell Comments on Dungeness Funding and Prioritisation Need for clarification No comment Query key activity Refer to other question Relationship between decommissioning and new build Site end state / end use Specific comment/suggestion Number of comments 1 3 1 2 4 3 7 2 1 1 3 1
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DA Draft Business Plan: Summary of submissions, February 2008
7.0
Dounreay Site Restoration Limited
Q. Do you have any comments on the key activities and/or key focus for the site managed by Dounreay Site Restoration Ltd? 14 people responded to this question although most of these had no comment to make. The comments that were received were expressing concern about focussing funding too narrowly on Dounreay, that Dounreay should be managed to minimise its impact on the environment and food chain and lastly that maybe particles on the sea bed should be dealt with first. Group Heading Funding and prioritisation General comment Need for clarification No comment Separate Sellafield/Dounreay from other sites Specific suggestion / comment Number of comments 1 1 1 7 1 3
8.0
Research Sites Restoration Limited
Q. Do you have any comments on the key activities and/or key focus for the site managed by Research Sites Restoration Ltd? 27 people responded to this question. The majority of responses received to this section were about the need to continue decommissioning at these sites. There is a view that these sites (Harwell and Winfrith) could easily have been fully decommissioned in the near future and would have been a good example of what could be achieved. The costs associated with stopping the work and then having to start again in the future are seen as being large and a waste. Group Heading Challenge prioritisation Comment on public consultation Loss of skills/knowledge Need for clarification Need to continue decommissioning at these sites No comment Specific comment/suggestion Number of comments 3 1 3 1 13 8 1
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DA Draft Business Plan: Summary of submissions, February 2008
9.0
Low Level Waste Repository Limited
Q. Do you have any comments on the key activities and/or key focus for the site managed by Low Level Waste Repository Ltd? 19 people responded to this question. Most of these comments were queries or suggestions relating to the key activities planned for the site. A couple of responses supported the focus for this site. Group Heading Comment key activities Comment on engagement plans General comment No comment See previous comment Specific comment/suggestion Support this focus Number of comments 7 1 1 6 1 1 2
10.0 Springfields Fuels Limited
Q. Do you have any comments on the key activities and/or key focus for the site managed by Springfields Fuels Ltd? 15 people responded to this question. As can be seen from the table below most had no comment to make whilst some had very specific suggestions regarding the marine environment, coastal waters and the food chain being taken into consideration when making decisions. Group Heading Maximise opportunities for Springfield Need for clarification No comment Specific suggestion/comment Support for this section Number of comments 2 2 8 3 1
11.0 Subsidiary Companies
Q. Do you have any comments on the key activities and/or key focus for International Nuclear Services or Direct Rail Services? (Please state which company you are referring to in your submission). 14 people responded to this question. Again most had no comment to make. The comments that were received though were mainly on Direct Rail Services. Types of
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comments were that DRS should be sold off to the private sector as it is peripheral to the NDA’s mission. Another was that other companies were able to offer the same services as DRS so should be put out to tender rather than being a ‘supplier of choice’. There was also concern expressed over NDA managing both of these companies as they are not seen as core to the NDA’s remit. Group Heading Comment on DRS Comment on INS Concern over NDA managing these companies Need for clarification No comment Number of comments 4 1 1 1 8
12.0 Any other comments?
25 people responded to this question. The majority of comments received were relating to the consultation process. These comments ranged from criticism of the draft plan to people welcoming the chance to comment. Group Heading Comment on consultation process Comment on new build Concern over prioritisation Concerns over competition Funding comments General observation Key strategic issues missing from Plan Need for clarification Need for common standards No comment Plan not consistent with Strategy Reconciling social economic effects Supply chain issues Number of comments 8 1 1 1 4 3 1 2 1 5 1 1 2
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DA Draft Business Plan: Summary of submissions, February 2008
Appendix 1: List of participants
Name 1 Paul Paul Steven. S.B. Ruth Richard Fred DI Colin Bill Carroll Jack Jill James Helen DR Malcolm Joseph Stuart M Sasha Phil Renee Valerie Archie Jeffrey Hugh Sandra Andy Sue Deborah Joe Martin Kean Kean Terry JP Campbell Terry Ann Jill Tony
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Surname 1 Allan Allan Anderson. Balogh Balogh Bardsley Barker Barlow Bayliss Bryce Buxton Callan Callander Carrick Cassidy Challen Chapman Clark Conney Crosbie Davies Davies Dempsey Drake Dryburgh Elliman Ellis Ellis Elsden Ferns Fisher Flanagan Forwood Franks Franks2 Fraser Gardner Gemmell Gilbert Goldsmith Graham Green
Organisation Dungeness Site Stakeholder Group Creca Village Hall Committee Radwise Limited Unite W Cumbria & N Lakes Friends of the Earth none NuLeAF Department for Transport AMEC/CH2MHILL/UKAEA Alliance Doosan Babcock Energy Limited HIE Caithness & Sutherland CECA Chapelcross Site Stakeholder Group Washington Division, URS Sellafield Ltd. Capenhurst LSG Magnox South UKAEA Food Standards Agency Isle of Anglesey County Council Individual Department of Environment, Heritage & Local Government Chapelcross T&G Section of Unite Individual Winfrith Site Stakeholder Group Nexia Solutions Ltd Prospect NWDA CORE Sussex Police Sussex Police Harwell-Chilton Campus Local Stakeholder Group Individual SEPA AMEC West Lakes Renaissance Magnox North
DA Draft Business Plan: Summary of submissions, February 2008
Richard Richard Neil Phil Mark Alan Norman Richard John Chris Kathy Philip Charles John Ray Terry Stewart Stuart Stuart Derek John Terry Neil June Kenneth Brian Valerie Rick John Frank Linda Fergus Jean Donald Peter Leonard Mark John Paul Andrew Geoffrey Sandra Margaret Keith Scot Phyllida Judith
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Greenwood Griffin Griffiths Hallington Harbor Haresnape Harrison Hartland Haywood Hill Hill Holland Holmes Isgoed Williams Johnson Jones Kemp Klosinski Klosinski Lacey Lamb Lawrence Lock Love Mac Dougall Main Mainwood McEvoy McGibbon McGurty McLean McMorrow McSorley McWilliam Montague Moore Morant Mouat Murphy Nunn Nutt Owsnett Palling Parker Parkhurst Parsloe Payne
Cumbria Vision Nuclear Decommissioning Authority Magnox North Union Representatives Committee Hunterston Site Stakeholder Group Sellafield Ltd UKAEA UKAEA The Highland Council West Cumbria Sites Stakeholder Group Caski Consulting Ltd Nuclear Decommissioning Forum SITA Allerdale Borough Council Trawsfynydd Site Stakeholder Group Channel Chamber of Commerce Cumbria County Council Furness Enterprise Limited Keep Our Future Afloat Campaign Nuclear Safety Directorate Hunterston SSG West Cumbria Business Cluster Dounreay Site Stakeholder Group Bradwell LCLC Bradwell for Renewable Energy
Young Generation Network Copeland Borough Council Greenpeace British Nuclear Group Project Services Magnox Federation of Community Councils Magnox Electric Ltd Shetland Islands Council Individual Suffolk Coastal District Council Individual UKAEA Individual Nuclear Industry Association Association for Consultancy and Engineering Thornbury Town Council Thornbury Town Council
DA Draft Business Plan: Summary of submissions, February 2008
Steven John David Andrew David Anonymous John Richard Ivor Andrew John Mike Barry John Michael Richard David Graeme Peter Joan Fredrik Juell Andy Martin Steve Bob Kerry Tom Keith Stuart Martin Rachel Stephen Bernard John Jackie Terry Sioned Penny
Payne Pitchford Polden Price Primrose Response Roberts Roper Roscoe Ross Sharp Short Sillito Simpson Slater Smith MVO Staniforth Stonell Sumner Taylor Theisen Thomas Thresher Tothill Treacher Trout Turner Waller Watson Weeks Western Whittingham Whittle Wilkins Wilkinson Williams Williams Wride
Berkeley Site Stakeholder Group Suffolk County Council London Region Campaign for Nuclear Disarmament Dorset county council Church of England Wylfa Site Stakeholder Group UKAEA Hunteston SSG UKAEA East Hendred Parish Council Individual Multi-design Consultants Prospect Branch of NUKEM Limited Sizewell 'A' & 'B' Site Stakeholder Group Individual UKAEA Nexia Solutions Kent & Essex Sea Fisheries Committee Norwegian Ministry of the Environment Future Solutions UKAEA Nukem Environment Agency
Costain
Freelance Department For Transport Springfields Site Stakeholder Group None SERENCYF Gwynedd Council Berkeley SSG
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DA Draft Business Plan: Summary of submissions, February 2008