What no decommissioning Strategy !!!

MODs' own reports acknowledge there is no funding to deliver the decommissioning strategy. However a properly funded decommissioning strategy is one of the key requirements for holding a nuclear site license in the civil sector, why should MOD be any different?

From the 2009 DNESB report

“Decommissioning & Disposal. 2005 issue 3 updated and reduced.
No Decommissioning and Disposal Strategy and no funded plan for decommissioning and disposal of submarine including adequate facilities to de-fuel them at the end of service life”

However the guidance from the HSE to inspectors on decommissioning nuclear licensed sites requires licensees’ to demonstrate that they have funding to carry out decommissioning and for state owned industry should describe their corresponding arrangements.

Extract from “NUCLEAR SAFETY DIRECTORATE GUIDANCE FOR INSPECTORS ON DECOMMISSIONING ON NUCLEAR LICENSED SITES

A2.3.14 Demonstration of Financial Provision

A2.3.14.1 Comprehensive estimates of the costs of decommissioning should be provided and linked to the activities to be carried out. All significant activities should be taken into account including corporate and general infrastructure responsibilities; radioactive waste management, storage and disposal; decontamination and dismantling works; care and maintenance; monitoring and surveillance and any other associated activities. Major cost components should be identified together with the distribution of costs with time. Any assumptions made on discount rates and the timescales over which they have been applied should be justified (see Appendix 6).

A2.3.14.2 Licensees should provide details of the arrangements for the funding of their nuclear liabilities. In the case of the privatised industry the financial provision is expected to be contained in segregated funds, kept separate from other company funds. The state owned industry should describe their corresponding arrangements. Licensees should provide a demonstration of the adequacy of the financial provision being made to implement the strategies. This should show that the strategy does not economically foreclose on earlier options for decommissioning, including an explanation of how the costs will change and the money will be provided if alternative options are chosen.”

Extract from a note by the Health & Safety Executive- Financial Implications of Licence Condition Compliance at NDA Sites:

“Financial Implications for Site Licensees
HSE clearly has an interest in whether the site license company (SLC) has reasonable expectation of access to sufficient resources to enable it to comply with all the Licence Conditions, and to have confidence that those resources will continue to be available at least for the term of the NDA contract. Confidence in the likely access to adequate and secure funding is one factor which HSE takes into account in its continuous assessment of whether an SLC is, and is likely to remain, a fit and proper body to hold the nuclear site licence (bearing in mind that if not happy with the SLC’s fitness, HSE has the power to revoke a licence at any time, and to impose suitable controls on the ex-licensee via Directions issued under the Nuclear Installations Act).”

The MOD is not subject regulation by the Nuclear Installations Act 1965 (NIA65) but subject to a system of internal regulation enforced by the Defence Nuclear Safety Regulator (DNSR); it is clear that DNSR lacks the regulatory power to ensure that the MOD decommissioning strategy is funded as would be the case on a civil site regulated by the HSE/NII.

If the MOD controlled nuclear activities were subject to regulation under the NIA65 it is worth considering if HSE would find the MOD fit and proper body to hold a nuclear site licence.

The lack of a funded decommissioning strategy provides powerful evidence of the need to apply the Nuclear Installation Act 1965 to MOD controlled nuclear activities.