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Policy Department D: Budgetary Affairs ____________________________________________________________________________________________ URS, AREVA and AMEC. But still the performance did not meet the planned level (NAO 2012). In total, only 3 of 14 projects are on or ahead of schedule (House of Commons 2013). The Sellafield Plan 2011 is, according to House of Commons Office, more credible than the 2007 plan, but it is not clear yet whether it is 'sufficiently robust' (House of Commons 2013). Still, since the 2007 plan was rejected by NDA as 'undeliverable' (NAO 2012), improvements in the project management are visible. The new Parent Body Organisation Nuclear Management Partners firstly carried out an assessment of all processes across Sellafield against industry best practice in order to identify areas where changes in the management are needed (NDA 2011b). The 2011 plan identifies the key plants and projects (NDA 2011b), but uncertainties in the Sellafield plan remain. NDA revised the plan, but had no robust benchmarks to make judgments on proposed levels of performance in order to accelerate the process (NAO 2012). The NDA could also not determine whether critical paths for completing programmes and projects were correctly identified, as the Sellafield plan did not clearly show dependencies between them (HM Treasury 2013). The NDA is trying to create a benchmarking tool to be rolled out in Sellafield (NAO 2012). The Sellafield plan is supported by other documents like e.g. the NDA strategy papers and Business Plans (see Figure 18). The NDA needs to update its decommissioning strategy every five years. In 2010 a public consultation about the new draft strategy was undertaken. According to the Energy Act 2004, the strategy has to be approved by the Secretary of State jointly with the Scottish Ministers. The first such strategy was produced in 2006 and revised in 2011 (NDA 2011c). The NDA Business plan sets out the near term objectives for a three year period. Figure 18: Relationship between several important documents Source: (NDA 2011a) According to the National Audit Office NDA and Sellafield Ltd suffer gaps in information and weakness in communication between each other. NDA did not collect enough robust and timely information on projects from Sellafield Ltd until 2011. Because of this they were unable to intervene in time (NAO 2012). The National Audit Office recommended an accurate and timely reporting and monitoring to be able to identify emerging issues early on NAO 2012. 74
Nuclear Decommissioning: Management of Costs and Risks ____________________________________________________________________________________________ 3.3.4. Risk management The Sellafield Plan 2011 sets out measures for risk reduction for several of the Sellafield projects (NDA 2011b). According to the findings of the National Audit Office the Sellafield plan 2007 'did not provide sufficient information to allow NDA to understand programme-level risks fully' (NAO 2012). According to NDA 'the Windscale programme is not on the critical path, therefore the programme has been subject to a number of deferrals' and the time and funds have been transferred to other projects (NDA 2013b). In 2011, the first fuel started to be removed from Calder Hall. This was the start of a six -year programme for removal and a significant step in risk and hazard reduction (NDA 2013c). The fuel is planned to be stored elsewhere at the Sellafield site for reprocessing. 3.3.5. Regulatory approach The Office of Nuclear Regulation, an agency of the Health and Safety Executive (HSE) formed in 2011, is responsible for the regulation of nuclear safety and security and the Environmental Agency is responsible for the regulation of environmental matters on nuclear sites including radioactive waste disposal (see NAO 2012). According to the Office of Nuclear Regulation the decommissioning is conducted normally in three stages (ONR 2013): Stage 1 - Post-operational clean out where the bulk of the radioactive material, such as fuel, is removed from the facility. Stage 2 - Initial dismantling and removal of contaminated parts or care and maintenance to allow radioactive materials to decay. Stage 3 - Dismantling of the facility, demolition of the structure; and remediation of land and water to meet an agreed end-state for future use. 3.3.6. Cost estimates Since most of the major projects at Sellafield are complex and unique, cost estimation is difficult and uncertainties remain. The Sellafield 2011 plan includes outline estimates for costs for key projects but did not provide sufficient data for reliable estimates. In its revision, the NDA found a lack of consistency in the contingency contained within the estimates (NAO 2012). The cost estimates in the past years have been increased on a drastic scale. In 2007 the total costs were estimated at £ 61 million, increasing in the 2013 estimate to £ 200 million (House of Commons 2013). This demonstrates the weakness of early cost estimates. The latter number is believed to be more credible than the one from 2007, but still uncertainties remain in the mid-term to 2026 as well as in the long-term to 2120 (NAO 2012). 3.3.7. Workforce Sellafield Ltd employs approximatively 10,000 people (NDA 2011b). The development of the workforce from 2011 to 2119 is shown in Figure 19. 75
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