Higher-activity radioactive waste: implementation strategy

3 Strategy Elements

3.1.1 The ethos of the Scottish Government HAW Policy is that radioactive waste should not be considered "out of sight, out of mind" and that there needs to be a continued oversight of the waste whether it is in storage or in a disposal facility.

3.1.2 Underpinning this ethos will be a need to ensure that storage and disposal concepts are both publically and technically acceptable. This section sets out the approach the Scottish Government will begin to take to help build stakeholder and public confidence and the regulatory requirements for future facilities.

3.1 Regulation

3.1.1 The concepts of monitoring and retrievability are a fundamental part of the 2011 Policy which states that " Developers will need to demonstrate how the facilities will be monitored and how waste packages, or waste could be retrieved." As storage and disposal concepts are progressed in Phase 2 monitoring and retrievability arrangements will be developed and reviewed.

Monitoring - Storage

3.1.2 The fundamental regulatory requirement is that there should be safe and secure interim storage arrangements, for the anticipated storage period, that ensure the protection of people and the environment. Such arrangements may assume a single store to cover the entire period, or may provide for replacement or refurbishment of stores at appropriate intervals. The adequacy of the storage arrangements needs to be justified in the safety case.

3.1.3 Details of ONR's monitoring/inspection requirements for radioactive waste and interim storage facilities are set out in a number of documents. The Scottish Government is of the view that monitoring of storage facilities is sufficiently well regulated.

Monitoring - Disposal

3.1.4 The presumption in the Policy is that, whilst no specific period is prescribed, current practice in the management of radioactive waste facilities reflects that up to 300 years is an acceptable period for institutional control and monitoring in a disposal facility.

3.1.5 The Policy sets out that a baseline would be required for monitoring to allow for future assessments to clearly identify the impact of a future disposal facility and its performance. Monitoring of non-radiological matter may also be required.

3.1.6The Policy also sets out that monitoring should set thresholds for specific contaminants, which trigger action if they are exceeded. As required by the GRA in the interests of avoiding placing an unreasonable emphasis on current or long-term future action, the safety of any future facility should not be reliant on post-authorisation period monitoring.

3.1.7The Scottish Government expects monitoring to be delivered in an open and participative manner, involving stakeholders and communities. Monitoring processes will have to be developed as the design of a near surface facility progresses.

Retrievability - Storage

3.1.8 When waste is managed in a store it is always on the basis that it will have to be retrieved. Current storage facilities therefore have retrievability and must demonstrate the continued ability to retrieve waste during the storage period to the satisfaction of the regulator, ONR.

Retrievability - Disposal

3.1.9 When waste is managed in a disposal facility it is on the basis that there is no intention to retrieve it. However, the concept of retrievability is an important issue for stakeholders and international experience demonstrates that it is now being considered in designing disposal facilities around the world.

3.1.10 The 2011 Policy does not specify how retrievability will be demonstrated, but states that it will be for developers and operators to include retrievability in the design and management plan for any storage or disposal facility to the satisfaction of the regulators.

3.1.11 As the design of a near-surface disposal facility is progressed further work will be required during the planning phase to ensure that retrievability is appropriately addressed.

Packaging of HAW

3.1.12All radioactive waste will need to be in a form suitable for its long-term management. Although waste packaging is the responsibility of the individual waste producers in Scotland it is subject to a robust regulatory assessment process.

3.1.13Waste producers and owners should continue to promote the importance of waste characterisation, improved waste information and waste segregation to facilitate planning. Characterisation at all stages of the waste management cycle is important. It can yield most benefit before materials become waste, which supports good decision making so as not to foreclose options.

3.1.14Scottish Government expects RWM to continue to work with waste producers to help ensure packages remain in a suitable form for long-term management and as appropriate, update guidance to support the development of near-surface disposal concepts.

Information and knowledge management

3.1.15The 2011 Policy recognises that there is a clear need for information and knowledge to be maintained within Scotland in the long-term to manage the waste. The preservation of records, knowledge and memory is an integral part of radioactive waste management.

3.1.16There is a need to consider how information and knowledge should be maintained so that it is accessible now and to future generations. Effective knowledge management allows individuals to capture, prioritise and further disseminate current and legacy knowledge, experience and expertise.

3.1.17To ensure effective knowledge and information management across the NDA estate, the NDA published an Information Governance Strategy in 2013 ^[10] . In 2014 the NDA and all NDA SLCs and subsidiaries assessed the risks and opportunities associated with the information created, managed and processed within their respective organisations and relevant supply chains in relation to the strategy. The NDA have now incorporated the findings from these and other reviews into an overarching NDA national programme.

3.1.18For longer term information management the NDA is currently proceeding with the next phase of the Nuclear Archive project which will see a new purpose built facility constructed at Wick to provide long-term management and storage of records and other archive material from civil nuclear sites in the UK. 'Nucleus - the Nuclear and Caithness Archive' is intended to be a centre of excellence in terms of information governance and addresses a number of mandated obligations required of the NDA.

3.2 Stakeholder Engagement

3.2.1 One of the fundamental principles of the 2011 Policy is that waste producers and owners, developers and operators of facilities must engage with stakeholders, and in particular local communities where any facilities may be located, at an early stage. The need for public confidence in the development and operation of new waste management facilities is an integral part of the Strategy.

3.2.2 UK and international research and experience has shown that building stakeholder confidence is key to making progress with implementing projects. Active engagement of stakeholders, especially in the early stages of a project, increases the chances of success and can create significant savings in the long-term.

3.2.3 The Scottish Government will participate in regular industry and government networks including NDA National Stakeholder Events. The Scottish Government will also continue to run Scottish Nuclear Sites meetings. Attendees include the NDA, CoRWM, SCCORS, Site Licence Companies, EDF Energy, NDA Site Stakeholder Groups and the regulators.

3.2.4 The NDA sponsors Site Stakeholder Groups ( SSGs) at existing sites, whose overarching purpose is to be the prime interface between the community, the nuclear site operator, and the NDA. It is recognised that the role and remit of the SSGs may change over the years, particularly when sites go into a Care and Maintenance phase. However, it will still be important during this stage of the work to ensure that there is an effective on-going line of communication between the site and the community.

3.2.5 The Scottish Government will continue to work closely with stakeholders, the NDA and other waste producers and owners to ensure there are effective dialogue mechanisms and to strengthen stakeholder confidence and inform policy development.

3.2.6 The Scottish Government will work with the NDA to review stakeholder engagement processes and methodologies to help significantly increase public participation as the strategy evolves and during the next Policy review. The Scottish Government expects the NDA, in consultation with SCCORS and COSLA, to review the local government participation process in Scotland to ensure that views on the nuclear legacy in Scotland from member local authorities and community councils are properly considered.

Community Engagement

3.2.7There are around 1200 community councils in Scotland, all of which are composed of elected volunteers from the community. Local authorities and other bodies consult with community councils on issues affecting the community. These issues depend to a large extent on what is important to each community, however, local authorities are required to consult community councils on planning applications and many choose to involve them in the community planning process.

3.2.8It is critical that communities in Scotland are informed at an early stage and engaged throughout the waste management decision making process. A near-surface facility is likely to bring significant economic benefits to a host community. These community benefits and the process for determining the appropriate level of community benefits will be developed during Phase 2.

3.2.9 It is one of the key principles set out in the GRA (guidance on requirements for authorisation of near-surface disposal facilities) that the developer should engage in dialogue with the planning authority, local community, other interested parties and the general public when developing an environmental safety case. Flexible approaches for engaging in discussions will be required that adapt to meet a community's needs and expectations.

3.2.10The developer will need to consider, in discussion with the relevant local authorities, how to define "local community" for any specific proposal, taking into account the nature, size and location of the proposed facility.

3.2.11Both the developer and the regulator should aim to work together to make sure that discussions with the planning authority and local community are open, inclusive and constructive. Technical, social or economic issues that might affect development of a disposal facility should be discussed openly with explanations of what the developer or regulator is doing to deal with these issues. Local communities and others should also be able to challenge the views of the developer and/or regulator on technical and other issues. Developers and operators should ensure transparency by providing opportunities for all stakeholders to participate in the decision making processes in accordance with national and international obligations.

3.2.12To support the establishment of a disposal facility concept the Scottish Government will work with COSLA, the Forum on Stakeholder Confidence and other independent experts to review existing community and stakeholder engagement processes and develop and implement a community and stakeholder engagement plan in Phase 2.

3.3 Skills and Supply Chain

3.3.1Decommissioning in Scotland will be spread over many years resulting in a life cycle in excess of 100 years. In this time period, under current plans, operation of remaining reactors will cease, sites will enter Care and Maintenance phases of quiescence and final site clearance will begin with reactor dismantlement and waste disposal. Skills, supply chain and staffing requirements required in each stage of decommissioning will be very different.

3.3.2The future need for a decommissioning workforce gives rise to a number of challenges:

• Retention of skills due to retirement of workforce. Over the next 15 years, at least 34% of the UK's nuclear workforce will reach retirement age ^[11] .
• Transfer of existing skill and competencies for a period of over 60 years whilst the sites are in Care and Maintenance under current planning assumption.
• Development of new skills and competencies in the area of decommissioning and radioactive waste management.

3.3.3The Scottish Government's skills strategy "Skills for Scotland: Accelerating the Recovery and Increasing Sustainable Economic Growth" ^[12] makes clear the Scottish Government's commitment to training and skills and sets out a flexible, responsive, partnership approach to meeting Scotland's skills needs. The NDA's People Strategy directly supports this and has demonstrated positive commitment to achieving those expectations. Apprenticeships, bursaries, engineering skills and infrastructure joint investments all are good examples of working together to a common aim.

3.3.4The Scottish Government is committed to working with industry to ensure that Scotland has the skilled workforce required for decommissioning. Launched in May 2013, through Scotland's skills body, 'Skills Development Scotland', with a budget of £6.5m (2012-13/2013-14), Energy Skills Scotland is working with industry to ensure that Scotland has the skilled workforce required to strengthen its overall ambition as a major centre for energy activity. In March 2015, Skills Development Scotland published a new Skills Investment Plan for the Energy Sector ^[13] . This refreshed plan was developed in partnership with the National Skills Academy for Nuclear and sets out key actions over 5 themes:

1.Inspiring and preparing young people to engage in the range of opportunities provided by the energy sectors

2.Developing pathways to enable more people to enter the sector

3.Ensuring content and mode of delivery of education and training provision meets the needs of industry

4.Upskilling to develop the existing workforce

5.Tackling the gender balance

6.Planning and coordination informed by good labour market intelligence

Figure 4: Strategies and actions plans for skills and knowledge retention

3.3.5The NDA recognises people with appropriate skills and capabilities are essential for delivering its Mission successfully. It is not only an obligation within the Energy Act 2004 to ensure that there is a skilled workforce available to undertake the work of decommissioning, but a fundamental principle to the success of the organisation, the SLCs and a responsive supply chain. The NDA have launched a variety of initiatives to ensure skill retention:

• The Skills and Capability Strategy (2008) ^[14] outlines the continued commitment to work with its contractors, supply chain and stakeholders to deliver its Mission through a focussed Action Plan.

• The People's Strategy (2010) ^[15] broadens its scope to encompass a more joined up approach to resource planning across the NDA estate with a view to explore the barriers to mobility of the workforce; identify and share good practice; and, produce a common approach within the NDA and SLCs of human resource related issues. The Strategy also focuses strongly on apprenticeships, and encouraging young people to consider a career in the industry. Almost 400 apprentices are now in place across the NDA and SLCs. The Strategy also covers the development and support for regional training centres, including the Engineering and Skills Centre at North Highland College.

• The People and Skills Strategy (2014) ^[16] updates the above 2008 and 2010 strategies to place a greater focus on collaboration and focus on the following areas:
  • Retraining and redeployment
  • Efficiency and effectiveness improvements
  • Resource/Infrastructure
  • Resource Planning
  • People Relations

3.3.6The NDA recognises the key role the supply chain plays in delivering its mission, with circa £135m spent in the supply chain at Dounreay in 2013/14 ^[17] , and 24% of this spent directly with Small and Medium Enterprises ( SMEs). In support of the supply chain/ SLCs the NDA:

Produced a Supply Chain Development Strategy (2010) ^[18] that aims to ensure the optimum use of the Supply Chain available to the NDA estate to enable a safe, affordable, cost effective, innovative and dynamic market for clean-up and decommissioning. It is broken down into four key areas and each area has a set of detailed principles supporting it: open, transparent, timely and consistent communications at all levels (including those that assist Tier 2/4 and SMEs); optimised supply chain processes; optimised supply chain relationships; and exploring synergies with other nuclear clients and industries.

Established a SME steering group for Scotland, to help with some of the current issues facing this critical group of suppliers. The NDA steering group provides a forum to discuss improving the attractiveness and health of the market that supports the NDA sites, with particular focus on SMEs in Scotland. The group consists of five to six SMEs with one or two representatives from the Scottish Government, NDA, SLCs and business support groups such as Scottish Enterprise and Highlands and Islands Enterprise. The chair of the group is an SME based in Scotland. The Scottish SME group also seeks to make links with the Oil and Gas industry decommissioning activities.

Scottish Development International will work with the NDA to identify nuclear decommissioning and radioactive waste management investment, trade or international collaboration opportunities that benefit Scotland.

3.3.7As appropriate, the Scottish Government will monitor and help co-ordinate work being undertaken by Skills Development Scotland, Scottish Enterprise, Highlands & Islands Enterprise and Scottish Development International to:

- review and enhance the Skills Investment Plan for the energy sector, to take account of skills shortages in the nuclear decommissioning sector in Scotland; and

- support initiatives such as the Nuclear Supply Chain ^[19] Project and participate in the NDA SME Steering Group

3.3.8 During Phase 1 of the Strategy consideration will need to be given to the work and retention of skilled people in particular SEPA/ ONR regulators. The Scottish Government will carefully plan for skill and knowledge retention over future decades including during periods of lower activity on sites.