RWMAC's Annual Report for 2000-2001

Annex 6

Ownership, Regulation and Operation of MoD Radioactive Waste Producing Sites

Notes

1. NNRP is part of MoD and is therefore the Ministry's own regulator. However, it is independent of the Navy operational line. For those parts of the NNPP not subject to the civil provisions, NNRP may be described as an "external" regulator. Where the NNPP is subject to the civil provisions, NNRP provides MoD with assurance.

2. It is believed that some liabilities may attach to DRDL in respect of the decommissioning of plant developed since privatisation of the two dockyard sites.

3. RWMAC believes there is a need for a central, unified, MoD "external" regulatory and assurance body.

4. A major role of NWIPT is management of the AWEML contract. As part of this role, NWIPT provides MoD with some assurance of the adequacy of the contractor's waste management and decommissioning plans.

5. DSEF-Pol maintains oversight arrangements for nuclear safety, radiation protection, and radioactive waste management within MoD and appears to have de-facto assurance responsibilities for the smaller defence sites. The various Health and Safety at Work Acts (HSWAs), and the Ionising Radiations Regulations (IRRs), apply to these, and all other, defence sites. The HSWAs and IRRs are regulated by the Health and Safety Executive (HSE) which has agreed a set of principles with MoD governing the interface between the organisations on defence sites not licensed under NIA65.