Page 1 Sellafield Integrated Waste Strategy Update to Version 2 June 2008 © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Progress Report on Version 2 June 2008 Page 2 of 61 This Page Intentionally Left Blank © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 3 of 61 Executive Summary The development and subsequent annual reporting of an Integrated Waste Strategy (IWS) for Sellafield addresses specific requirements within the Radioactive Substances Act 1993 Authorisation for Sellafield site, Nuclear Site Licence Condition 32, and the contractual arrangements between Sellafield Limited and the Nuclear Decommissioning Authority (NDA). This report provides an update in the steps which continue to progress towards a fully integrated and optimised waste strategy. It is written as an addendum to the 2007 IWS (Version 2) report and the reader should refer to Version 2 for further context and background. Vision, Aims and Objectives The Sellafield IWS is a live strategy, subject to annual review and update, which provides the rationale behind the waste strategy aspects of the Sellafield site Lifetime Plan (LTP). It is a subset of the Integrated Strategy for Sellafield which considers a wider range of factors such as hazard and risk reduction, commercial goals, national policy and affordability. The Vision of the IWS for Sellafield was described in Version 1 (June 2006) as: An Integrated Waste Strategy will deliver an operating site that has minimised waste generation and where waste is generated, it is contained in a manner that achieves sustainability; where sustainability is waste in a form that requires ideally nil, but probably minimal, management to safely protect people and environment including the remediation of historical impacts. To support this vision, the site aims to continually develop an IWS and pursue Waste Minimisation and Sustainability. The IWS achieves these aims by: providing an overview of wastes on the Sellafield site providing a methodology for practicable application of the Waste Management Hierarchy (WMH) enabling the site to envisage and develop waste routings identifying opportunities and challenges within future waste routings facilitating holistic management of wastes and making waste management arrangements more transparent informing site strategies and enabling top-down direction setting to drive the business The rate of progress in implementing the IWS is influenced by: a) the need to be consistent with a higher strategic driver for the site of ‘hazard and environmental risk reduction’ b) affordability of the implementation plan in any given period Scope This report summarises the progress and developments since the IWS was last reported, by Version 2, in June 2007. It addresses: • how component waste strategies have developed since June 2007 • the impact that the previous version of the IWS (Version 2) had on the plans and strategies included in compiling the next LTP • new drivers that have gained prominence since the IWS was last reported As such, this report is considered to be an “update” to the previous version of the IWS rather than a new version. This update therefore summarises the current state of implementation of the waste management strategy covering radioactive and non-radioactive solid, aqueous and gaseous wastes and any material which has the potential to become waste in the future. Exclusions In agreement with the NDA this annual update specifically excludes a full scale revision to the full document format as prescribed by the NDA procedure ENG 01. Rather this addendum is intended to provide a fit-for-purpose update to the current status of the IWS for Sellafield. Also excluded are Windscale and the National Nuclear Laboratory (NNL); spent or irradiated fuel, and uranium and plutonium, as these are not classified as wastes. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 4 of 61 Progress The IWS has developed from being a statement of the baseline waste management strategy at Version 1 (June 2006), to an integrated strategy for the future in Version 2 (June 2007). Since Version 2 considerable progress has been made in translating this strategy into the LTPs for the site. In particular: • all wastes and routes have been identified • estimated quantities of waste have been reassessed for both raw and conditioned volumes • Opportunities have been identified for waste minimisation and the use of existing facilities. These have either been incorporated into the LTP or identified for further assessment. • Strategies for implementation are being developed for Low Level Waste (LLW), Intermediate Level Waste (ILW) and Plutonium Contaminated Material (PCM) • Tools and techniques to facilitate quantification and assessment and to enable the visible management of wastes information have been developed e.g. Sankey Diagrams in Version 2 and the Overall Effluent Strategy Model (OESM). • The analysis has contributed to the NDA-led national strategies, in particular ILW and LLW strategies. By following the structured process, developed in Version 2, and embedding the outputs of this into LTP the site has made significant progress towards its goal of transforming the IWS into a functional everyday aid for the strategy team and site management, and hence to the site for running our business and addressing the stated aims of the IWS. The largely ‘integrated’ position established by Version 2 (June 2007) has been successfully strengthened in the past 12 months through the tactical deployment of the IWS principles developed in IWS Version 2 (2007) within the component waste strategies and operating unit work plans. Furthermore, the methodology followed gives the site confidence that, based on current assumptions, it has successfully identified: • its wastes inventory and arisings profiles • their routings and any potential bottlenecks • the potential new plants and routes required to appropriately treat and dispose of these wastes These findings have been implemented, as appropriate, into the LTP developed for the site. Uncertainties There remain considerable uncertainties which pose a challenge to the development of an integrated and optimised IWS. Specifically, current prominent uncertainties include the necessary financial provision to deliver the current strategy, technical challenges, and the consequential impact these uncertainties may have on the timing of other supporting strategies. These uncertainties are outside of IWS control and future development of the IWS will be informed by the outcome of work which is currently ongoing to better define and resolve these uncertainties. Additionally, the Department for Environment, Food and Rural Affairs (DEFRA) review of the UK Discharge Strategy, the subject of a period of public consultation this summer, has the potential to further impact on the site strategy. Risks The IWS can be potentiality impacted by a number of future risks. The current risks can be grouped under three high-level categories: • LLW – Risks are dominated by the uncertainty that surrounds the Low Level Waste Repository (LLWR) regarding potential changes in waste acceptance criteria, future capacity and the potential for disposal costs to rise. • ILW – Many of the risks for ILW arise from the current uncertainties surrounding the deep repository, including delays in availability, which would extend current store lifetimes, and changes in acceptance criteria which may lead to rework or over-packing for existing packages. • Site Wide – These include risks associated with the major operations of the site, such as concern about the High Activity evaporative capability, fuel reprocessing throughput and available funding adversely affecting execution of the LTP, such as the Legacy Ponds and Legacy Silos (LP&LS) schedule. Work is being done to mitigate these risks within the individual Operating Units (OUs) on site. Opportunities © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 5 of 61 The IWS and supporting component strategies have identified a number of opportunities. If realised these have the potential to further integrate and optimise the IWS. The opportunities for LLW are largely related to initiating new processes for avoiding and minimising the volume of LLW requiring disposal. These include techniques such as improved waste segregation and characterisation, chemical decontamination, cracking and crushing of concrete, and cable stripping. In addition there are considerable opportunities regarding the on site reuse and recycle of High Volume Very Low Level Waste (HVVLLW). These are being developed via the LLW Strategy for the Sellafield site, due in January 2009. The opportunities for ILW involve rationalising the number of potential treatment plants and stores required by pursuing opportunities to use existing and planned ILW treatment plants to treat additional wastes and, in the case of stores, exploring options relating to the rate of export of waste packages to the ILW repository. The timescales for decisions to be taken for the different opportunities varies considerably, and is largely dependant on the predicted schedule of waste generation. Some of the opportunities identified within this version of the IWS have interdependencies with decisions required to be taken at a national level, e.g. the national LLW strategy and decisions relating to the ILW Repository. The development of a national IWS by the NDA would help to facilitate the resolution of key uncertainties. Future Development The IWS will continue to develop for the foreseeable future as: • the component strategies develop and progress • other external influences affect the strategic direction of the site and the timing of certain key decisions • the interactions between strategies and the opportunities they create continue to be optimised In the near term, the following will influence the development of the Sellafield IWS: 1. development of national strategies, such as that for LLW, due in early 2009 2. requirement for a combined Sellafield and Windscale IWS by the end of June 2009 3. financial provision for work and projects required by the site strategy This update of the IWS reports and discusses the tactics and deployment of the Sellafield IWS. The component strategies will continue to implement the principles of the IWS and hence the future 1 development of the IWS will primarily be as a ‘flankguard ’ role to: • ensure the general strategic direction is maintained, regardless of changes to tactics that may be needed in the future • undertake assessment of potential strategic changes initiated by resolution of uncertainties or changes in assumptions Paul Foster Director Strategy and Transition Chair of IWS Steering Group 1 ‘Flankguard’ – The role of flankguard to is continuously assess all internal and external changes arising after delivery of a strategy and their impact on the strategy and associated projects i.e. to keep the strategy “live”. It is also to ensure that the intent of the strategy is preserved during all subsequent implementation phases. The flankguard must also ensure the strategy is communicated to and understood by the teams carrying out the implementation phases. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 6 of 61 Contents EXECUTIVE SUMMARY ........................................................................................................................ 3 1.0 INTRODUCTION........................................................................................................................ 7 1.1 1.2 1.3 1.4 2.0 Sellafield Integrated Waste Strategy ........................................................................ 7 Successes in Waste Management on Sellafield Site .............................................. 10 What has changed since the previous IWS was issued in June 2007 (Version 2) .. 11 Impact of the Integrated Waste Strategy on the Sellafield Site ............................... 12 REVIEW OF PROGRESS ON THE 2007 IWS OUTPUTS...................................................... 13 2.1 2.2 3.0 The IWS 2007 Recommendations and the Progress made against them. .............. 13 Progress against the 2007 IWS (Version 2) Action Plan......................................... 22 STRATEGIC DEVELOPMENTS IMPACTING ON IWS.......................................................... 23 3.1 3.2 3.3 3.4 4.0 Other Strategic developments in the Sellafield Lifetime Plan (2008)....................... 24 Strategic Governance Arrangements ..................................................................... 26 Contaminated Land & Site End States ................................................................... 27 Integration with Windscale ..................................................................................... 28 PROGRESS MADE ON WASTE MANAGEMENT STRATEGIES ......................................... 28 4.1 Solid Wastes .......................................................................................................... 29 4.1.1 4.1.2 4.1.3 4.1.3.1 4.1.3.2 4.1.3.3 4.1.3.4 4.1.4 4.2 Update to the solid radioactive waste strategy................................................................ 29 High Level Waste (HLW) strategy ................................................................................... 31 Intermediate-Level Waste Strategy Update .................................................................... 33 Operational wastes ..................................................................................................... 33 Legacy Ponds and Legacy Silo wastes ...................................................................... 34 PCM wastes ................................................................................................................ 34 Final Treatment and Disposal of ILW.......................................................................... 35 Low Level Waste strategy ............................................................................................... 36 Aqueous Waste Strategy........................................................................................ 38 4.2.1 Sellafield Ltd’s response to the Particulate Enforcement Notice .................................... 43 4.2.2 Legacy Ponds & Legacy Silos – SIXEP Contingency Plan............................................. 43 4.2.3 Switching feeds from the Segregated Effluent Treatment Plant to the Enhanced Actinide Removal Plant................................................................................................................................ 44 4.2.4 Future Low Active Aqueous Effluent Strategy................................................................. 46 4.2.5 Discharge Trends ............................................................................................................ 49 4.3 Gaseous Waste Strategy ....................................................................................... 50 4.3.1 4.3.2 4.3.3 4.3.4 4.4 Decommissioning................................................................................................... 52 4.4.1 4.5 Update of the Gaseous Waste Strategy.......................................................................... 50 Separation Area Ventilation Project ................................................................................ 50 Alpha Plant Discharge Stack........................................................................................... 51 Discharge Trends ............................................................................................................ 51 Decommissioning Strategy (including mandates) ........................................................... 52 Non-Radioactive Discharges .................................................................................. 53 5.0 OPPORTUNITIES, RISKS & UNCERTAINTIES..................................................................... 54 6.0 CONCLUSIONS & WAY FORWARD...................................................................................... 55 7.0 GLOSSARY ............................................................................................................................. 59 © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 7 of 61 1.0 Introduction 1. This report is the third annual issue of the Integrated Waste Strategy (IWS) for Sellafield. It has been written as an addendum to the 2007 IWS (Version 2) and reports progress against the recommendations made in the 2007 IWS, recent developments in strategic governance arrangements for the Sellafield site, the latest waste strategies, and waste and effluent arisings data. As such, it should be read in conjunction with the 2007 IWS (Version 2) in order to fully understand the context of the information presented herein. 2. The delivery of an IWS for the Sellafield site is a formal requirement of Schedule 9 of the Radioactive Substances Act Authorisation (RSA 93) and helps demonstrate compliance with the Nuclear Site Licence, in particular Condition 32. 3. The Nuclear Decommissioning Authority (NDA) is responsible for the liabilities of UK public sector civil nuclear sites. The NDA requires each Site Licence Company (SLC) to produce an IWS; this should act as a tool for the site operators to optimise their site-wide approach to waste management. The NDA aims of the IWS are to: Protect people and the environment and respond to stakeholder concerns Make the most effective use of existing waste management facilities Provide value for money for the UK taxpayer Provide the link to the rationale behind the waste aspects of the site’s Lifetime Plan (LTP) submission Provide a framework for optimising the approaches to waste management on a site-wide basis. 4. It is the intention that the strategies set out in the individual site IWS reports will be rolled-up by the NDA at a national level and will be subject to periodic review. This will enable the NDA to identify strategic issues at both site and national level and thus to develop appropriate plans for the resolution of these issues. 1.1 Sellafield Integrated Waste Strategy The Sellafield IWS Vision is: 5. An Integrated Waste Strategy will deliver an operating site that has minimised waste generation and where waste is generated, it is contained in a manner that achieves sustainability; where sustainability is waste in a form that requires ideally nil, but probably minimal, management to safely protect people and environment including the remediation of historical impacts. 6. In addition to fulfilling the aims of the NDA given in paragraph 3 above, it is the goal of the Sellafield site to transform the IWS into a functional everyday aid for the strategy team and site management, and hence to the site for running our business. With this in mind, the IWS issued in June 2007 (Version 2) was developed with the following aims: a) to provide a consistent and proportionate overview of all wastes on site ensuring that the Waste Management Hierarchy (WMH) is applied wherever practicable and due consideration is given to the interaction between environmental protection and urgent hazard reduction; b) to envisage how the site waste routings will develop over time; c) by means of b), to identify bottlenecks in waste handling and to open up new waste routes where appropriate; d) to produce a Decision Calendar for the new facilities suggested by c); e) to encourage the shift in behaviours necessary to get the new waste routes in use at the working level; f) to facilitate customer, Regulator and stakeholder engagement. 7. The rate of progress in implementing the IWS is influenced by: • the need to be consistent with a higher strategic driver for the site of ‘hazard and environmental risk reduction’; • affordability of the implementation plan in any given period. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 8 of 61 8. IWS Version 2 addressed these aims via a structured process of applying the WMH and using Sankey 2 Diagrams to identify areas for improvement. The process inherently recognises the priorities of safety and 3 risk reduction and applies the NDA Prioritisation Logic , the WMH and the principles of Engineered 4 Destinations . Full details of this process can be found in section 7 of the IWS issued in June 2007 (Version 2). 9. By following this structured process and embedding the outputs of this into the LTP (see section 1.4 of this report) the site has made significant progress towards its goal of transforming the IWS into a functional everyday aid for the strategy team and hence to the site for running our business and addressing the aims a) – f) given above. 10. Sellafield site comprises more than 200 nuclear facilities, in various different stages of building life, from operations to decommissioning, and with some new plants under construction to enable the site to deal with legacy wastes. Sellafield is a key part of the nuclear fuel cycle. The size and complexity of the site and the wide range of wastes inevitably means that the corresponding waste strategies and management arrangements are multifaceted, requiring significant effort to become truly integrated and optimised. The IWS is a component part of the Integrated Strategy for Sellafield, and the links between component strategies and external influences is shown in Figure 1 below, which also highlights the strategies that come under the ‘IWS’ banner. 2 Sankey Diagrams have been used to illustrate the waste arisings at key snapshots in time and the currently identified routings for these wastes. The concept of Sankey Diagrams is described as; the thickness of the lines is representative of the (volumetric) flows of the waste, and the relative size of the ‘arrows’ on the diagrams represents the waste treatment plant throughput capacity for the given year. From this, bottlenecks and waste routes are visually easy to assess. 3 The Energy Act, and the NDA Management Statement and Financial Memorandum, places requirements on the NDA in respect to performance reporting, openness and transparency, and for ensuring that the rationale for major decisions, and the processes by which they are reached, are clear to stakeholders and the wider public. One of the ways in which the NDA achieves this is by a national process for work prioritisation. This is used as an aid to the effective scheduling of remediation work optimising the SLC delivery against the Site Funding Limit (SFL), and to assess alternative delivery strategies. As such the Prioritisation Process has been designed as an aid to decision making, which supports the development of the Life Time Plan (LTP). For further information refer to the NDA website, www.nda.gov.uk 4 Engineered Destinations: The final form (solid, aqueous, gaseous) of radioactivity determines the environmental impact arising from that waste. Ideally the activity is retained within a form that offers maximum ‘barriers to the biosphere’ i.e. an engineered form that limits the pathways for discharge to the environment. In practice this means that generally the preference is for activity to be captured in the solid form rather than aqueous form which is in turn preferred to the gaseous form. Unintentional, uncontrolled discharge to ground must be avoided. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 9 of 61 Figure 1 – The interaction between site strategies, the IWS and external influences from UK and NDA policies 11. The methodology followed in the 2007 IWS, that was built on the baseline position established the previous year, has given the site confidence that based on current assumptions it has successfully identified: • its wastes inventory and arisings profiles • their routings and any potential bottlenecks • the potential new plants and routes required to appropriately treat and dispose of these wastes These findings have been implemented as appropriate into the LTP developed for the site. 12. The Sellafield IWS is still progressing towards being fully integrated and optimised and will continue to do so for the foreseeable future as: • the component strategies develop and progress • other external influences affect the strategic direction of the site and the timing of certain key decisions • the interactions between strategies and the opportunities they create continue to be optimised 13. This is illustrated in Figure 2 below, which explains how the Sellafield IWS report has developed through a number of stages. Initially, a baseline position (produced in 2006) where objectives and inventory were identified, together with a basic strategy. This progressed through to an analytical tool (IWS Version 2 2007) that assessed waste routes and identified bottlenecks and opportunities for improving application of the WMH to give a more developed strategy and some tactical application of this. This report represents the current position, which is a summary of how the IWS has been tactically deployed on the site at the working level and the changes this has engendered (2008, this report). 14. The tactical deployment has been achieved by the IWS team and the wider Strategy Group through addressing the recommendations of the 2007 IWS, attending strategy meetings, engaging with stakeholders, and encouraging work streams and projects to adopt the principles identified in the 2007 IWS. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 10 of 61 Figure 2 – The development and progression of the IWS 15. It has been recognised that owing to the complexity of the Sellafield site and associated wastes and waste routes that it will take a number of years to produce an optimised and fully integrated strategy for wastes. This report therefore provides an update in the steps towards a fully integrated and optimised waste strategy. 16. This addendum reports the progress since the issue of Version 2 (June 2007) and discusses: • how component waste strategies have developed since Version 2 • the impact that IWS Version 2 had on the plans and strategies included in the 2008 LTP • new drivers that have gained prominence since the IWS was last reported. 1.2 Successes in Waste Management on Sellafield Site 17. Significant amounts of waste have successfully been treated at Sellafield, thus greatly reducing hazard, volume, and risk, resulting in a much lower environmental impact. This demonstrates the benefits of waste management planning which are being further strengthened through deploying an IWS. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 11 of 61 18. Examples of recent successes in waste management include: 900te of metals have been decontaminated via the Wheelabration process. The metal is assessed and characterised as suitable for exemption under RSA 93, then shot blasted to remove surface films down to bare metal. Further reassurance monitoring is carried out prior to release to a scrap metal dealer for recycling. The Wheelabrator safety case has been successfully modified to further allow the processing (and hence decontamination) of stainless-steels. Clearance and characterisation of Thorp Medium Active Salt-Free Evaporator (MASFE) wastes – Improved characterisation enabled declassification of the waste, which meant that the waste could go to landfill or the Low Level Waste Repository (LLWR) as appropriate, saving £100,000 Characterisation of the asbestos from the decommissioning the Calder Hall power station heat exchangers – the entire waste stream was successfully characterised for exemption under RSA 93 through appropriate sampling. This therefore negates the need for monitoring every single bag of waste. Completion of waste oil treatment and disposal trials – Oil incineration at Studsvik (a specialist waste disposal company), established the process viability. Thermal energy produced during the incineration was used to heat the buildings on the Studsvik site (energy recovery). Public engagement has taken place concerning the treatment of Low Level Waste (LLW); covering Oils, Metal, Asbestos, Process Waste and High Volume Low Active (HVLA) wastes. Individual stakeholder engagement sessions were held (presentations, questionnaires and final reports are on the “Consultations” area of the Sellafield Ltd Web Site www.sellafieldsites.com/page/corporate-responsibility/stakeholder-engagement/consultations) Achieved >65% packing efficiency overall for LLW containers sent to LLWR for all containers where appropriate infill material was available. This reduces the amount of clean grout used at the LLWR and improves the utilisation of the space in the LLWR Recycling of Fluorescent Tubes via monitoring and using a waste contractor rather than crushing and disposing to the LLWR – trialled and now this good practice in one part of the site is being applied site-wide (where applicable). Improved waste concentration rates in the Enhanced Actinide Removal Plant (EARP) provide a significant (20-30%) reduction in the future lifetime arisings of the associated Intermediate Level Waste (ILW) packages produced. This also helps to secure the ongoing processing schedule of historic waste recovery through the EARP process. 19. 1.3 In recognition of the magnitude of the decommissioning task facing Sellafield site, a database has been developed to centralise individual decommissioning project information to look for trends. As the information is amassed, it should be possible to improve predictions of waste volumes for future decommissioning and demolition projects, and enable assessment of these against the capability of the various treatment and disposal routes. The database aims to provide gains in the key areas of data defensibility, data applicability, data collection, cost savings and data collection timelines. The database will include access to real-time links of underpinning information and will have an ability to identify programme or project constraints and measure their impacts. What has changed since the previous IWS was issued in June 2007 (Version 2) 20. Since the previous IWS was issued in June 2007 (Version 2), there have been significant external influences upon the Sellafield site and subsequently upon the Integrated Waste Strategy. 21. A 7 Point Plan has been agreed between the NDA and Sellafield Ltd to act as a route map in preparation for the transition to a new Parent Body Organisation (PBO) for the Sellafield site. This included a work stream aimed at improving the arrangements for hazard reduction and the implementation of an integrated strategy between the NDA and the SLC. The 7 Point Plan is the high-level short-term strategy for the business, and is essentially a collection of work streams, many of which are already underway. These work streams have been jointly agreed by Sellafield Ltd Executive and the NDA as areas important to the success of the business both today and into the future. Whilst this plan does not cover all existing activities across Sellafield Ltd, these are those elements which have been identified by the executive team as © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 12 of 61 having key strategic significance. The successful execution of the 7 Point Plan will result in improvements in all areas of the business, in particular in nuclear, radiological, conventional and environmental safety. The elements that are most pertinent to the IWS are those involving improvements in strategic planning and governance. 22. Previously (in Version 2, published in 2007), it was noted that the IWS is a subset of the Integrated Strategy for Sellafield and as such is influenced by constraints and dependencies arising from: Financial provisions – The NDA own the liabilities of the Sellafield site, with the SLC (Sellafield Ltd) operating the facilities on the site and decommissioning areas of the site under contract to, and on behalf of, the NDA. The NDA is funded by the Treasury of the UK Government, and is subject to the government comprehensive spending review. As such the cost of decommissioning the Sellafield site is ultimately borne by the UK taxpayer. The plans submitted to the NDA for operating and decommissioning the Sellafield site are known as the “LTP”, and have been produced on a yearly basis for the last 4 years. Timing – The complexity and multifaceted aspect of the Sellafield site ensures that the timing and scheduling of plant operations, decommissioning, waste retrieval, infrastructure, and new-build projects all have cross-connections and subsequent influences upon each other. Therefore even relatively basic changes to one aspect of strategy or operational scheduling can have a profound impact across many areas of the Sellafield site. Technical – The Sellafield site is one of the most complex and crowded nuclear sites in the world, and to ensure continued excellence in nuclear safety and nuclear material management requires significant technical expertise and understanding. There are a number of technical constraints associated with radioactive waste management and as such these have an influence upon the Sellafield IWS. Transport strategies – Moving raw and conditioned waste around the site as required for treatment or storage, and exporting waste to repositories for disposal as appropriate. Ongoing strategy development for Site End States & Contaminated Land – The final end state(s) for the Sellafield site and the extent to which any contaminated land is treated or excavated for treatment will have a large impact on the Sellafield IWS. 23. There have been significant developments in several of these areas, notably: Financial provisions – The funding that has been made available to the site is insufficient to fully deliver the planned scope of work. As a consequence, the site is re-evaluating its LTP against the available funding profile. Timing - Work programmes have altered & extended to take into account the funding constraints. Technical – Technical challenges on the High Active (HA) Evaporators are presently constraining the throughput & capacity of upstream plants and have extended the Thorp and Magnox reprocessing dates, causing subsequent changes in the timing of other supporting strategies. This report explores these developments and reports the consequential impacts on the IWS in section 3. 24. The future development of the IWS will continue to be informed by the outcome of work that is currently ongoing to better define and resolve these uncertainties. 1.4 Impact of the Integrated Waste Strategy on the Sellafield Site 25. The recommendations and findings made by the IWS Version 2 (issued June 2007) have been implemented into the future work planned on the Sellafield site through the LTP process. A short list of some of the most relevant is provided here: Volume reduction facilities, expansion of the LLW decontamination capacity and opportunities for High Volume Very Low Level Waste (HVVLLW) reuse/recycle are being progressed by the developing LLW strategy. Sort & Segregation and decontamination opportunities for ILW are included within the Final Treatment and Disposal of ILW Operating Unit (OU). Two options studies (as detailed in section 2.1) were delivered and will inform both the LLW and ILW strategies for the site. 26. The IWS has also informed some future Research & Development (R&D) requirements of the site. These can be found in the site’s Technical Baseline Underpinning Research & Development (TBURD). A short list of some of the most relevant R&D Tasks is provided here: Improved waste characterisation & radiometric segregation and sorting is required. Source decontamination methods to increase amount of ventilation ductwork sent as LLW instead of Plutonium Contaminated Material (PCM). © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 13 of 61 Determine the depth of contamination in mild and stainless steels and explore methods of decontaminating stainless steel. Identify techniques / technologies for reducing volumes of contaminated soil requiring disposal. Size reduction / alternative routing for non-compactable materials. Underpinning studies for LLW Incineration. Underpinning studies relevant to encapsulation of reactive metals. Assessment of the feasibility of decontaminating ex-Decommissioning ILW. Investigate means to minimise decommissioning ILW product yields i.e. active grouted ILW, and coconditioning of slurry and bulk ILW. Investigate In-cell segregation of LLW from ILW. Investigate the compaction of waste filters to reduce packing space. Develop instrumentation to characterise cell concrete for ‘free release’. It should be noted that constraints on funding are likely to impact upon the R&D described here and in the TBURD and hence prioritisation of the R&D carried out may mean some or all of these are delayed or cancelled. 2.0 Review of Progress on the 2007 IWS Outputs 27. Improvements were identified within the IWS Version 2 process and these came in two forms, firstly a series of key recommendations for improvement, and secondly an action plan to deliver them. The action plan, whilst taking note of the key recommendations, has been influenced further by RSA 93 authorisation requirements, NDA Performance Based Incentive (PBI) S003-07/08-35-15 for Sellafield site, and other findings from the IWS Version 2 process, for example, review by the Integrated Waste Strategy Steering Group (IWSSG). 28. This section reports on the progress made in relation to the various recommendations. The work done on each recommendation is discussed together with a summary of the progress made by the site. 2.1 The IWS 2007 Recommendations and the Progress made against them. 29. Recommendation 1: Develop and trial a structured process for WMH application within Decommissioning Mandates 30. Progress Made: Decommissioning Mandates have been carried out on 22 plants to date, including the major facilities on site. As part of the mandates, waste quantities have been assessed and the output of the mandates is currently being reviewed, including an assessment of sensitivities of waste volumes and waste treatment options. The contract for the Decommissioning Mandates was already in place when this recommendation was made in the 2007 IWS (Version 2). Therefore, the site was unable to impose this additional work on the mandates due to commercial constraints. Currently no further Decommissioning Mandates are planned for Financial Year 08/09. This recommendation is therefore on hold while the way forward with the Mandates is determined. 31. Recommendation 2: Carry out a review to establish optimum scrubber liquor routing & treatment of current Segregated Effluent Treatment Plant (SETP) routed liquors 32. Progress Made: After verifying that no such review had historically taken place, a ‘Scrubber Particulate’ Workshop was organised to bring together the technical expertise of the various OUs which operate scrubbers at Sellafield, independent engineering expertise within Process Engineering, Nuclear Ventilation Design Group and the IWS. 33. The purpose of the workshop was to ascertain whether particulates present an issue for the individual scrubber liquor streams, and if so consider alternatives to optimise the routing. The key conclusions are summarised below: 1. There are no target or success criteria by which to judge the acceptability of particulates in scrubber liquor sent to SETP. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 14 of 61 2. It is not practical to effectively sample for very small levels of particulate in the relatively large scrubber bleed streams. 3. Prediction of particulates in scrubber liquor based on source terms can only be done on a worst case basis. 34. Actions were placed against those OUs where a scrubber wasn’t represented at the workshop or where further information on a particular scrubber system is required to confirm that robust Best Practicable Means (BPM) are in force. A summary report will be produced, to include the programme of work to further progress this issue. 35. Recommendation 3: Establish robust characterisation and capability to sort and segregate LLW and ILW waste from decommissioning 36. Progress Made: There is a significant quantity of waste scheduled to arise from decommissioning. Current estimates 3 3 3 indicate approximately 891,000 m of LLW, 66,000 m of ILW and 1,408,000 m of Very Low Level Waste (VLLW) to arise through decommissioning over the remaining lifetime of the site. 37. There is a strong driver to have appropriate segregation of materials at the decommissioning workface and to avoid mixing wastes in the first instance. This is especially applicable during decommissioning activities where the volumes are large and the potential for waste segregation exists. The projected volumes of decommissioning wastes have been revised based on information from some of the recently completed decommissioning mandates. These mandates assume techniques to decommission specific plants and assess the associated cost and projected waste volumes using one set of assumptions. Subsequent work on the mandates will assess the range of techniques, volumes, costs & timescales which may be may be adopted for decommissioning in practice. 38. Recognising the large volumes of wastes projected to arise over the lifetime of the site, the LLW Management OU has included the concept of new-build facilities (subject to selection of the Best Practicable Environmental Option (BPEO)) within its 2008 LTP assumptions. These facilities will enable a greater degree of waste minimisation (although the new build will in itself produce waste, the overall long term impact will be a net reduction in waste) in order to reduce the total volume consigned to the current LLWR and successor facility. A series of public consultations have taken place as a preliminary investigation of these concepts. Within these conceptual new-build facilities, a sort and segregation capability is included that will segregate waste both radio-metrically and by material type. The facility is to also include segregation of wastes not only from decommissioning but also from operational and Post Operational Clean Out (POCO) activities. 39. The LLW sort and segregation facility is assumed to become operational in 2020 and is being further developed as part of the LLW strategy which will be published in January 2009. It is currently the intent that the facility should be able to segregate wastes that are suitable for: Thermal treatment, Melting / smelting, Low Force Compaction, Non-compactable wastes, Metals suitable for mechanical decontamination (wheelabration), EXEMPT materials. 40. Appropriate segregation of ILW by material type is included within the scope of the Final Treatment and Disposal of ILW strategy. The degree of segregation required is mainly driven by the extent to which it is necessary in order to achieve a suitable final waste product for disposal. Volume reduction is currently assumed to be an opportunity in the Final Treatment and Disposal of ILW OU strategy. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 15 of 61 41. It is worth noting that the two IWS Option Studies produced both highlighted the need for robust characterisation and the capability to sort & segregate waste. This was further reiterated in the output from the series of public engagement workshops on LLW that have taken place since the IWS Version 2 was issued. 42. Recommendation 4: Ensure the re-use and recycling of materials such as High Volume VLLW and cables and switchgear generated from decommissioning 43. Progress Made: This recommendation has been addressed by the completion of an option study, specifically looking into the reuse and recycle of HVVLLW. Focus was given to HVVLLW arising from decommissioning, for example concrete, rubble and metals. Cables and switchgear were left outside the scope of the option study, since the volumes generated were considerably less than the other material types. 44. Over the lifetime of the site, it is predicted that 1.4M m of HVVLLW will be generated. HVVLLW is defined as radioactive waste that has an activity lying between the exemption level of 0.4 Bq/g, and 4 Bq/g. At present all HVVLLW generated is to be disposed of to a specified landfill, as stated in 2007 LTP. There are both commercial and ethical incentives for the investigation of potential routes that will enable reuse or recycling of this waste. Largely speaking, these entail being able to prevent costly disposal, whilst preserving the environment from the impact of transportation of the waste on such a large scale. In a strategic sense, there is therefore considerable scope for the improved application of the waste management hierarchy. 3 Located here for illustrative purposes Figure 3 – Sellafield site, yellow circle indicates the volume of land needed for the disposal of all HVVLLW, assumed depth of 10m 45. The intention of the option study was to evaluate a range of possible scenarios and thus recommend a viable case for further waste route development, whilst also informing future strategic thinking. The three scenarios investigated are provided below. This enabled the issue to be bounded; scenarios 1 and 3 are the two extremes of either doing the minimum possible or doing everything to reuse / recycle waste. Scenario 2 is the “middle ground”, whereby HVVLLW would be recycled wherever practicable, though with an option for waste to be disposed off-site to a specified landfill as necessary. 46. Scenarios 1. Disposal of all HVVLLW to specified landfill (Current situation remains the same) 2. A combination of reusing and recycling HVVLLW on site, and the disposal of waste to a specified landfill if deemed necessary 3. All HVVLLW to be reused or recycled on site, with no disposal to off-site landfill 47. From here, the scenarios were critically assessed, investigating practicable routes in which to implement the particular scenario. The assessment would be made both quantitatively and qualitatively, against a number of metrics; these were Cost & Schedule, Security, Safety and Environmental Impact. Table 1 gives the specific details and comparative costs of each of the scenarios. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 16 of 61 48. From the investigation, it became apparent that there was not significant variation in the overall costs associated with the different scenarios. It should be remembered that these costs are indicative only, and are not a detailed costing or business case. Furthermore, it was realised that certain variables were responsible for a major proportion of the costs, for example the predicted cost of characterisation. This led to the first recommendation of the IWS option study, as summarised below. The option study has been developed alongside a spreadsheet, which has been used as a tool to construct the quantitative argument. The spreadsheet has been developed with an inherent level of Table 1 – Summary of the details and indicative cost of each scenario flexibility, allowing for change and Scenario Details Costs progress to be incorporated in the Calder Landfill Extension Segregated 5 1 future, thus ensuring the option Areas (CLESA) filled and then all waste to £1257M Specified Landfill, 150 km to site study is a robust, adaptable, and onSegregating exempt from HVVLLW. All going process. 2 exempt reused on site, HVVLLW disposed of to CLESA and then specified landfill Segregating exempt from HVVLLW. All exempt reused on site, HVVLLW used as sea defences and end state landscaping Segregating exempt from HVVLLW. All exempt reused on site, all HVVLLW used as end state landscaping Segregating exempt from HVVLLW. All exempt reused on site, all HVVLLW used as LLWR capping £1060M It was concluded that potential reuse/recycle routes that did not 3a £1078M involve further characterisation would be financially beneficial. This may include using HVVLLW as 3b £1094M capping material for the LLWR or as landscaping material for the £1019M 3c implementation of the end-state vision of Sellafield. There is scope for all HVVLLW to be used in some form on Sellafield site, for this reason it was concluded that all HVVLLW should remain on site. By doing do this would mitigate the considerable transport, environmental and safety implications associated with transporting the waste off site. A list of some of the key recommendations to come out of the option study are provided below: • • • • 49. Identify and minimise the true costs of waste characterisation, as they currently form the most significant cost in all strategic options for the reuse and recycle of HVVLLW. A detailed assessment of the amount of waste exemption that would be achieved through improved waste characterisation should be undertaken. Assess the statistical risk of reuse and disposal on-site for comparison against the risk from transporting all HVVLLW to an off-site specified landfill. Investigate the potential use of Sellafield HVVLLW concrete and rubble as capping material for the LLWR. 50. The output of this options study is being used to inform the developing LLW Strategy. 51. Recommendation 5: Increase the Sellafield waste volume reduction capability 52. Progress Made: The 2008 LTP strategy for LLW includes a suite of new-build treatment facilities that are assumed to commence operations in 2020. These facilities are intended to provide a greater degree of volume reduction than that which currently exists on the site and hence will minimise the overall quantity for disposal to the LLWR or successor facility. The facilities are also assumed to generate waste products that will comply with the LLWR conditions for acceptance. 53. The LLW facilities that are to achieve significant volume reduction are as follows: Continued use of the Waste Materials and Compaction (WAMAC) facility for high force compaction of compactable LLW until 2020, A new facility for Thermal destruction of suitable LLW from 2020 onwards, A new facility for Melting / Smelting of suitable LLW from 2020 onwards, 5 CLESA is an area of Sellafield site that is treated as a landfill for low activity waste. The capacity is limited to 100,000 m3, and the activity limit of acceptable materials is 37 Bq/g © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 17 of 61 A new facility for Low Force Compaction of any compactable LLW that cannot be processed via the above facilities, Continued use of mechanical decontamination of LLW in the form of the current wheelabrator 54. Early analysis carried out as part of the 2008 LTP strategy development for LLW indicates that the impact from the new facilities results in approximately 19,300 fewer Half Height International Standards Organisation (HHISO) freights required for disposal over the lifetime of the site. This is illustrated in Figure 14 in Section 4.1.4 of this report. 55. Volume reduction of PCM is currently achieved through high force compaction via the current Waste Treatment Complex (WTC)1a facility. The 2008 LTP strategy for PCM includes a new PCM treatment complex for processing any PCM wastes that are not suitable for the current compaction process in WTC1a. The process for the new treatment complex has not yet been finalised and the primary driver will be to achieve a safe and passive waste product suitable for repository disposal. Volume reduction potential will also be considered in the selection of the final process. 56. Similarly, the primary driver for the ILW strategy is to achieve a safe and passive waste product suitable for repository disposal. Volume reduction is currently included as an opportunity and is being investigated as part of the strategy for the Final Treatment and Disposal of ILW OU. 57. Recommendation 6: Perform a Study on Passivation Requirements and Alternative Encapsulants for ILW 58. Progress Made: This recommendation has been captured within the TBURD. This means that the need for specific research and development to resolve this issue has been identified in a key document underpinning the LTP. 59. This has been extracted from the TBURD section of the Sellafield LTP and repeated here for ease of viewing. Technical need – Task + gap Optimising OPC (Ordinary Portland Cement) grout formulations Identify optimum OPC grout formulations for each characteristic type of ILW within the scope of the Final Treatment and Disposal of ILW OU. Alternative ILW encapsulants Identify and characterise potential alternative encapsulants per each fundamental ILW type to be encountered within the scope of the Final Treatment and Disposal of ILW OU Context of why a problem (driver) Whilst OPC-based grout is the baseline ILW encapsulation medium, the term encompasses a wide range of OPC grades with and without additives (plasticizers, BFS, PFA etc). The process of identifying formulations per waste characterisation of alternatives. Whilst historically, OPC-based encapsulation matrices have been widely used for the conditioning of ILW, there are a number of drivers to develop comprehensive appreciation of alternative media – these include the potential need for:• encapsulants accommodating of wastes comprising / containing reactive materials and/or organics – in order to obviate / minimise the need for prior passivation of the wastes • encapsulants yielding low-leach wasteforms – noting that leach rate might become a key repository criterion with regard to meeting the Post Closure Report Safety Assessment (PCRSA) risk target or otherwise in order to justify BPM – particularly in respect of radionuclides that dominate the PCRSA • encapsulants with low thermal fracture potential due to waste decay heat – Potential alternative encapsulants include: OPC-based, other mineral-based, thermoplastic polymer, thermosetting polymer, bitumastic, vitreous, white metal, noble metal. Required characterisation data suitable OPC type entails Target Date Key outputs / Actions Exercise starts beginning 2010/11 and completes end 2012/13 (3 years total) Technical report (+ underpinning analysis and experimental results) recommending definitive OPC grout formulations per each Final Treatment and Disposal of ILW OU waste type Target date basis = critical path to inform design of 1st ILW treatment plant Exercise starts beginning 2010/11 and completes end 2014/15 (5 years total) Target date basis = critical path to inform ILW design of 1st treatment plant Technical report (+ underpinning analysis and experimental results) confirming suitable alternative encapsulants per each Final Treatment and Disposal of ILW OU waste type © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 18 of 61 Technical need – Task + gap Context of why a problem (driver) per encapsulant will include:- particular relevance is to irradiated U fuel residues. (Thermal fracture reduces product integrity pre-disposal and increases inrepository leach rate due to increase in specific surface) 1. 2. 3. 4. 5. 6. 7. ingredient costs ingredient availability ingredient shelf life method(s) of preparation method(s) of deployment flow characteristics incorporation limits vs. waste type 8. pre-cure / post-cure reactivity vs. waste type 9. performance sensitivity 10. curing characteristics 11. properties of cured matrix Alternative techniques encapsulation Determine practicable alternative encapsulation techniques for each perm of fundamental ILW type vs. viable encapsulant as determined at Final Treatment and Disposal of ILW-TB-RD3 • encapsulants with high tensile strength and / or low potential for chronic expansive reaction (within matrix or between matrix and waste) - thereby being resistive to matrix fracture (Matrix fracture reduces product integrity pre-disposal and increases in-repository leach rate due to increase in specific surface) • alternatives to OPC-base encapsulants should topical ingredients become scarce Gravity percolation (with/without vibro-assist) and paddle mixing – are the only two ILW encapsulation techniques that have been developed and implemented at Sellafield – in either case unplasticised OPC based encapsulants are used and waste feeds limited to:• fuel-element cladding (swarf and hulls etc.) and ferrous engineering scrap ex magnox and oxide reprocessing • acid and alkaline slurries ex oxide reprocessing • flocs ex treatment of site liquid effluents Target Date Key outputs / Actions Exercise starts beginning 2010/11 and completes end 2012/13 (3 years total) Technical report (+ underpinning analysis and experimental results) identifying practicable alternative encapsulation techniques for each perm of fundamental ILW type vs. encapsulant as determined at Final Treatment and Disposal of ILW OU - TB-RD3 Target date basis = critical path to inform design of 1st ILW treatment plant New capital facilities will be required to effect the conditioning of:• the lifetime inventory of the Miscellaneous Beta Gamma Waste Store (MBGWS) • the lifetime inventory of AGR (Advanced Gas Reactor) graphite and stainless steel • ex decommissioning ILW arisings up to the site end state - with encapsulation likely to be the predominant method employed. In this regard and in order to facilitate the specification and design of the new facilities, an objective appreciation of practicable alternative encapsulation techniques vs. waste types vs. encapsulants is required. 60. As noted previously, constraints on funding are likely to impact on the R&D that is performed, and the subsequent prioritisation of R&D work may mean some of all of these are deferred or cancelled. 61. Recommendation 7: Widen the envelope of the current LLW decontamination facility 62. Progress Made: 63. The current LLW metal decontamination capability on Sellafield site is in the form of two dry abrasive decontamination facilities (wheelabrators). One of which has been successfully decontaminating metals to the exemption levels, as specified by the RSA 1993, for the last ten years. The second wheelabrator gained the appropriate authorisation to accept, and thus decontaminate metals of confirmed contamination in November 2007. At which point both wheelabrators were now able to decontaminate metals from C2 2 2 Controlled Area levels of contamination (4 to 40 Bq/cm β, or 0.4 to 4 Bq/cm α – note that this is a measure of surface area contamination) down to exempt levels (0.4Bq/g), this demonstrates an increased capacity for LLW decontamination. The wheelabrators use a method of shot-blasting (an example of mechanical abrasion) to decontaminate metallic objects of simple geometries (Figure 4). In addition to this, © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 19 of 61 there is the ability for size reduction, using both cold and hot cutting techniques. Size reduction is used ensure that the metal objects are of a geometry that is acceptable for the wheelabrator process. Figure 4 – Pieces of metal before and after treatment (top and bottom left), one of the current wheelabrator facilities on site (right). 64. Due to the schedule of waste arising, the amount of stainless steel being generated as a result of decommissioning activities is increasing. Fuel storage pond furniture, such as the frames that hold MultiElement Bottles (MEBs), forms the majority of stainless steel waste. The increasing generation of stainless steel wastes has provided the motivation to widen the scope of the wheelabrator size reduction capability. Currently only cold cutting is permitted for stainless steel because of the potential hazard of chromium inhalation. It is anticipated that a Plant Modification Proposal (PMP) will be prepared that will substantiate the facility’s ventilation system against the increased hazard posed by chromium within the stainless steel. 65. The increased demand for decontaminating stainless steel has brought to light difficulties regarding the shot blast media currently used. Due to the nature of stainless steel, contamination can lie much deeper in the surface than for carbon or mild steel. For this reason the grit needs to be more abrasive. Currently, there are trials taking place investigating alternative shot blast media (grit). There is a high level of confidence regarding the potential success of these trials. 66. By the end of the year it is hoped that a minimum of 80 tonnes of stainless steel will released as clean or exempt waste. The increased volume of stainless steel being process by the wheelabrator has no effect on the cost of process or overall throughput. It should be noted that stainless steel is able to be sold for roughly £750 per tonne once decontaminated, as opposed to around £70 per tonne for other ferrous metals. This has a significant positive impact on the net cost of the process. 67. The potential for chemical decontamination of metals is currently identified as an opportunity in the site’s developing LLW strategy. 68. Recommendation 8: Carry out a Decontamination Option Study including assessment of electro-chemical techniques 69. Progress Made: The objective of the study was to review and assess the varying techniques for decontamination and thus inform future strategy development for the management of contaminated metals. The focus of the study was placed upon decontaminating LLW metals to become exempt from regulatory control. LLW is classified as waste that contains less than 12,000 Bq/g of beta/gamma activity (or 4,000 Bq/g Alpha), whilst any waste with less that 0.4 Bq/g of activity is classed as exempt. If proved successful, there was the potential for the process to be applied to ILW metals. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 20 of 61 70. At present a wheelabrator is used, however the capacity is currently limited by type of metal and geometry of waste handled. The motivation for improved decontamination is based on the preservation of capacity at the LLWR; in addition it is compliant with the WMH and can potentially lead to commercial gains from avoiding costly disposal and the resale of clean metals. 71. Figure 5 gives an indication of the volumes of LLW metals likely to be generated over the lifetime of the 3 site. An estimated 460,000 m of LLW metals are to be produced, the vast majority of which will be carbon and mild steel, as shown in Figure 6. Approximately 92% of all LLW metals will be carbon and mild steel, other metals such as stainless steel, aluminium, lead, zinc and copper contribute to the remaining 8%. Figure 5 18,000 500,000 16,000 450,000 400,000 14,000 Annual Volume (m 3) 300,000 10,000 250,000 8,000 200,000 6,000 The study was bound by three scenarios. This gave the study focus, from which the merits of each could be analysed. The three scenarios studied are shown below. Scenarios 1 and 3 are the extremes, whereby either the current situation remains or all waste metal are decontaminated. Scenario two is a compromise, in which the metal is decontaminated where practicable, however disposal is still an option. 1. 2. 3. Capability for decontamination remains the same as present - combination of current wheelabrator and disposal techniques. Employ decontamination techniques to treat LLW to exempt where practicable and if possible, ILW to LLW or exempt. All metal waste to be decontaminated from ILW to LLW and then through to exempt. 150,000 4,000 100,000 2,000 50,000 0 0 20 07 20 / 08 11 20 / 12 15 20 / 16 19 20 / 20 23 20 / 24 27 20 / 28 31 20 / 32 35 20 / 36 39 20 / 40 43 20 / 44 47 20 / 48 51 20 / 52 55 20 / 56 59 20 / 60 63 20 / 64 67 20 / 68 71 20 / 72 75 20 / 76 79 20 / 80 83 20 / 84 87 20 / 88 91 20 / 92 95 20 / 96 99 21 / 00 03 21 / 04 07 21 / 08 11 21 / 12 15 21 / 16 19 /2 0 72. Financial Year Metal Figure 6 Other 28 0.007% Carbon and Mild Steel 375,287 91.738% Zinc 18 0.004% Lead 989 0.242% Carbon and Mild Steel 73. Cumlative Metal Copper 518 0.127% Aluminium 529 0.129% Stainless Steel Stainless Steel 31,719 7.754% Aluminium Copper Lead Zinc Other The study investigated practicable routes in which to implement each particular scenario. From here these routes were assessed both quantitatively and Figure 5 - Cumulative and annual LLW arising profile qualitatively, against a number of metrics; these were Figure 6 - Pie chart showing the contribution made by the Cost & Schedule, Security, Safety and Environmental different types of metals to the total LLW metals arising Impact. Table 2 gives the specific details and costs of over the lifetime of the site each of the scenarios. A spreadsheet was produced in conjunction with the report, providing the quantitative argument. Within which all associated reasonable costs and characteristics are included, for example, capital and operational costs, disposal costs, decontamination factors. In addition, the spreadsheet has been constructed in such a way that ensures the study to be an adaptable piece of work, able to evolve as the situation progresses, and thus continue to provide a basis for strategic thinking. Table 2 – Summary of the details and indicative cost of each scenario It should be remembered that the costs shown in Table 2 are given as guidance only; they are not a detailed costing that might be £1068M expected to result from a design study. From a monetary point of view it can be seen that scenario 2 £1092M is favoured. This is because both costly disposal at the LLWR and £1146M expensive additional treatment plants are avoided. Having said this, the variation in cost between the £1294M scenarios is marginal. For this reason other factors have a greater importance, such as the application of the WMH. It was concluded that it would be both economically and environmentally beneficial for Sellafield to have an additional LLW decontamination facility. However, Scenario Details 1 Current wheelabrator remains Decontaminate LLW metals to 2a exempt where practicable: Wheelabrator + Chemical Pickling Decontaminate LLW metals to 2b exempt where practicable: Wheelabrator + Electrochemical All metal waste decontaminated 3b through to exempt: Wheelabrator + Chemical Pickling + Flux Smelt All metal waste decontaminated 3c through to exempt: Wheelabrator + Electrochemical + Flux Smelt Costs £1121M 74. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Cumulative Volume (m 3) 350,000 12,000 Page 21 of 61 further work is needed to underpin the cost analysis, and thus the business case. The following provides the key recommendations to come out of the LLW decontamination option study. • • • Initiate a project to assess the case for taking forward LLW metal decontamination – focussing on Chemical Pickling and Flux Smelting, but also considering Electro-polishing for more difficult items. Based on current LTP assumptions the timescale for decisions is relatively short owing to the arising of several large waste streams (around 10,000 te of metal) around 2020. Maintain the current site Wheelabrator capability for use in decontaminating LLW metals where practicable. This is recommended despite when the potential cost of operation of the wheelabrator may occasionally be marginally higher than the simple cost of direct disposal to the LLWR, and this can be considered the “cost of going green” i.e. doing the right thing with waste. Assess the regulatory implications and consider provision of LLW metals temporary storage areas at Sellafield to enable any decontamination plants to work at an efficient capacity and within a reasonable plant life, i.e. to smooth the waste arisings profile. 75. The output of the options study will inform the developing LLW Strategy. 76. Recommendation 9: Ensure that equipment re-use is considered when developing decommissioning plans 77. Progress Made: This recommendation was included during discussions within the Decommissioning Mandate process. Although it is noted that this strategic opportunity requires more detailed consideration during scheduling and project planning of decommissioning operations. It is recommended that further discussion and influencing of the Decommissioning Strategy and Decommissioning OU is needed, together with a wider consideration of potential reuse of plant & equipment during decommissioning, such as temporary overbuildings, Poly Vinyl Chloride (PVC), Personal Protective Equipment (PPE), etc. The site currently uses the internal intranet for a ‘sharing scheme’ for reusing equipment from decommissioned or redundant buildings. This recommendation will be pursued as and when there is further development of the Decommissioning Mandates and the Decommissioning Strategy. 78. Recommendation 10: Investigate the options for re-use of waste and materials rendered from decommissioning and demolition 79. Progress Made: This recommendation has been progressed mainly by the two IWS Option Studies (one on Reuse / Recycle of HVVLLW, and one on Decontamination of Bulk Metals). These option studies are discussed in more detail in the sections for Recommendation 4 and 8 above, but it is worth noting that they considered the potential reuse of waste & materials from decommissioning and demolition. 80. The revised decommissioning estimation process also considers potential reuse of materials, and the developing LLW Strategy discussed the potential reuse of waste and materials during the recent stakeholder engagement workshops, the output of which can be found at http://sellafieldsites.co.uk/page/corporate-responsibility/stakeholder-engagement/consultations 81. The development of the Sellafield IWS, which encompasses and integrates all the past, present and future wastes at Sellafield, both radioactive and non-radioactive, is a long term project and will take several years to complete. 82. Engaging with stakeholders is an important aspect in the development of the Sellafield IWS as it enables us to discuss key findings and obtain the stakeholders views. The output from these engagements informs the development of future versions of the Sellafield IWS. Version 2 of the IWS was presented to Stakeholders in June 2007. It was noted during the engagement that identification of stakeholders and matching the communications to their needs is very important for going forward. 83. Sellafield Ltd fully appreciate that stakeholder engagement is a two-way process and can be initiated by either one or more of our stakeholders or by Sellafield Ltd. We always endeavour to be as responsive and flexible as possible to our stakeholder’s requirements. Stakeholders who wish to initiate engagement with us to more fully develop the Sellafield IWS would be welcome. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 22 of 61 2.2 Progress against the 2007 IWS (Version 2) Action Plan 84. The recommendations from the 2007 IWS (Version 2) were developed into an action plan to ensure the recommendations were addressed in a suitable time-frame. The table below shows the action plan together with a summary of the outputs of the actions taken. Table 3 - IWS Version 2 Action Plan showing completion of actions Area IWS Improvement Plan (requirement of NDA PBI S00307/08-35-15 and RSA 93 schedule 9 requirement) Define key performance metrics (RSA 93 schedule 9 requirement) Identify and agree (with NDA) 2 specific areas to target improved understanding. To inform improved understanding within IWS Version 3 Findings of Version 2 to inform 2008 LTP Learning from experience (LFE) from ongoing decommissioning projects Key recommendations made in IWS Version 2 Section 7 Action Plan Produce an IWS ‘improvement programme’, addressing the improvement of the IWS for Version 3 and beyond to manage the risks and opportunities identified in Version 2. The ‘cost benefit matrix’ will be used to assign the priority and benefit/timing assessment in conjunction with affordability will provide the schedule input. Produce interim metrics Produce metrics Timescale End August 2007 Conduct options studies for these two specific areas: HVLA Decontamination options Summary report of interim status – end March 2008 Options studies by end June 2008 Demonstrate: Changes to waste strategy between submission of IWS Version 2 and the 2008 LTP submission Any additional waste strategy risks and opportunities identified between submission of IWS Version 2 and the 2008 LTP submission Actions the site intends to pursue under 2008 LTP to improve future versions of the IWS and to manage the risks and opportunities identified in IWS Version 2. Develop a process for capturing and exploiting LFE from ongoing decommissioning projects. Use this information to improve definition of approaches, define characterisation techniques and methodologies as key enablers to future application of the WMH. Demonstrate progress in refining estimates of volumes of wastes generated from decommissioning. The recommendations in Section 7.1 will be assessed for 2008 LTP implementation, following the process established for LTP production Implementation of these recommendations in line with the timescales agreed in the LTP March 2008 COMPLETED – Document produced (GEN-2097A) issued to st the NDA on 31 March 2008 March 2008 COMPLETED – Data Quality Objectives (DQO) Process & Database developed and demonstrated to the NDA as part of PBI (GEN-2098A). September 2007 COMPLETED as priorities / resources / commercial constraints have allowed – See Section 2.1 Sept 2007 May 2008 Action Taken COMPLETED – GEN1945A COMPLETED – Key Performance Indicators (KPIs) defined and agreed with the NDA to revised timetable. Provided to the NDA on th 30 June 2008 COMPLETED – See Section 2.1of this report. Options studies produced. Issued to the st NDA on 31 March 2008 © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 23 of 61 Area IWSSG review of IWS further opportunities Action Plan Conduct a workshop to identify opportunities that could be created by potential radical concepts/change in policy direction. Workshop to comprise of membership of IWSSG plus other key individuals as appropriate Output to inform future iterations of IWS Timescale October 2007 End June 2008 Non-radioactive wastes within IWS Improve definition of non-rad dataset for IWS Version 3. End June 2008 Behavioural changes to support implementation of recommendations Confirm the correct cultural changes required (e.g. target setting, Sellafield Site Procedures (SSPs), awareness training) Identify and initiate means of affecting these behavioural changes Communicate findings of IWS within internal ‘stakeholder community’. Utilise existing communications routes and target plants and projects most affected. Via existing mechanisms obtain regulator and internal stakeholder buy-in (note may require some changes in established positions e.g. interim inert raw waste storage) End December 2007 End June 2008 3.0 End October 2007 Action Taken IWSSG Minutes from th meeting on 20 August 2007. Originally planning this for October 2007, however, the IWSSG considered it appropriate to delay this workshop until sufficient management attention can be devoted to it, once the site priorities are resolved – likely to be circa April 2009 NO PROGRESS - due to funding & resource limitations - Refer to Section 4.5 ONGOING A series of internal communications on the IWS have taken place. Strategic Developments impacting on IWS 85. There have been several other developments at Sellafield since the IWS V2 was issued in June 2007 which together with some external influences, impact upon the overall site strategic development and the IWS. These are discussed in the sections below. 86. Funding As already mentioned, the funding on the site means that the current LTP developed for operating and decommissioning the Sellafield site is not presently fully funded and hence cannot be progressed as planned. The scope and schedule of the LTP is being reassessed. If the schedule for retrievals and decommissioning has to be extended there will be an increased overall cost for decommissioning the Sellafield site owing to extended operating lifetimes for plants and infrastructure and the stop-start nature of decommissioning operations that will be engendered. The site is currently reassessing the strategy against available funds, which will be used to inform future LTPs. The site has developed a list of site priorities based on the NDA Prioritisation Index, and hence the shortfall in funding means that lower priority work will be rescheduled in favour of progressing higher priority work. In addition to funding it is becoming apparent that the workload facing the site is placing considerable demand on scarce resources across the UK. This also needs to be taken into account when scheduling project work and work done to implement the IWS. 87. UK Discharge Strategy Review by DEFRA The ongoing Department for Environment, Food and Rural Affairs (DEFRA) review of the UK Discharge Strategy may have an impact upon the Sellafield site and hence upon the Sellafield IWS. The review is currently issued for consultation. Hence assessment of any impact this may have on this document is not possible at this time. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 24 of 61 88. 2008 LTP The development and delivery of the 2008 LTP for Sellafield was subject to a number of major changes and challenges. The impact of these, and completion of a jointly agreed Strategic Review with the NDA, resulted in a delay to the commencement of the production of the plan. Despite the challenging timescales, the 2008 LTP was presented in March 2008 to the Sellafield Executive for review and approval. As the plan did not reflect further advised strategic changes the Executive concluded it would be premature for Sellafield Ltd to endorse the 2008 LTP. The plan however will help to serve as the Control Baseline for 2008/09, providing a governance and performance reporting framework. A copy of the unapproved plan has been delivered to the NDA for information. Work is now underway to produce a way forward that addresses the requirements of the Regulators, the NDA and the SLC (Sellafield Ltd). Whilst this work is ongoing the gaps and issues identified in the current plan will be addressed and the LTP updated accordingly. Updating of the plan will be managed via the Master Project List using a Real Time LTP process. 89. National LLW Strategy The NDA has recently begun development of a national LLW strategy. Sellafield Ltd is therefore producing the Sellafield LLW Strategy for January 2009 that will help inform the developing national strategy. This is discussed in greater detail in a later section of this report (section 4.1.4 – LLW Strategy) 3.1 Other Strategic developments in the Sellafield Lifetime Plan (2008) 90. Reprocessing Timelines There are a number of strategic changes in 2008 LTP that have arisen due to factors other than the IWS, and some of these will impact upon the IWS. The most significant are the decisions to extend the operational period of both Thorp and Magnox reprocessing. Figure 7 displays the situation diagrammatically, highlighting the two main contributing factors, and also the key aspects of the site that are affected as a result. Figure 7 – Knock-on effect of extended Thorp and Magnox operational periods © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 25 of 61 High Level Waste Plants (HLWP) evaporative capacity impact on THORP strategy 91. It was assumed in the 2007 version of the IWS (Version 2) that Thorp would be operational at the rate programmed in 2008 LTP. The assessed date when HA Evaporator (Evaporator D) will be available for processing HA liquors is likely to limit Thorp throughput. This has a significant impact on the site strategies as it extends the operational life of Thorp and subsequent downstream facilities. Legacy Ponds & Legacy Silos 92. The Legacy Ponds & Legacy Silos (LP&LS) strategy remains unchanged apart from some tactical aspects of the strategy implementation that have affected the delivery timescales of key projects, as shown below: Figure 8 – Legacy Ponds & Legacy Silos Schedule 93. Figure 8 shows the schedule for the various plants that make up LP & LS. These are the revised dates since the publication of Version 2. The ponds and silos have had their retrievals schedules extended by 13 years. Those plants without an extension noted on the graphic are the treatment plants that will process the waste. It follows that they are also pushed back by a similar timescale. Site Ion Exchange Plant (SIXEP) waste processing is in the early stages of design, however it can be assumed to be operational in line with SIXEP waste retrieval dates. 94. Owing to the changes in funding and regulatory constraints, this change in programme scheduling is a good example of how the IWS strategic process is applied, i.e. strategy conception, deployment, tactics and finally flankguarding the strategy to changes, in this case funding. This process is referred to earlier in this report, within Figure 8. This also demonstrates good strategic governance, such that as the changes in funding and regulatory constraints were assessed and the consequential modifications were communicated using the strategic governance arrangements on the site. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 26 of 61 3.2 Strategic Governance Arrangements 95. In producing the IWS for Sellafield it was recognised that the arrangements for strategic governance of the site included elements of duplication. The Strategic Authority at Sellafield undertook to review and revise the arrangements. In addition, the NDA included a performance incentive (PBI element 2 PAF S003-07/0835-15) for the improvement of this issue to be delivered alongside the IWS. 96. This section provides a summary of the restructured governance arrangements for the Sellafield site. 97. The NDA are reviewing their arrangements for acting as the strategic mind. Therefore, the strategic governance arrangements summarised in this section should be considered as ‘interim arrangements’ whilst the NDA further develop their arrangements for the ‘strategic mind’ and until the transition to the new PBO is complete. 98. In the most part, the previous arrangements have been largely successful, however a number of recent changes have challenged the adequacy of the previous format of strategic governance. These changes come from three sources; firstly, the desire of the NDA to strengthen its role as the strategic mind. Secondly, a mismatch between funding, resources, and the schedule of work required to be done over the next three years, and finally, the recent production of the 7 Point Plan business strategy and the need for it to be aligned with the technical and engineering strategy. For these reasons the strategic governance arrangements were revised. A number of options were considered and the preferred option that was taken was to enhance existing arrangements. Table 4 provides a summary of the new strategic governance arrangements. Table 4 – Current Strategic Governance Arrangements Enhance Existing Arrangements Structure Integrated Waste Strategy Board of Executives (Strategy Steering Groups) Nuclear Decommissioning Production & Major Projects Group Operations Pros - Cons - Notes - - 99. 7 Point Plan Infrastructure Builds on existing strengths Integrates business and technical strategies Allows the executive to concentrate on only the most important issues Retains detailed knowledge puts higher workload on the executive to understand and make strategic decisions Duplicates resources Executive have a more active role in directing business, technical and engineering strategies. It does not allow decisions to be taken outside these forums IWS remains unchanged with any outputs being fed to the Executive strategy group. To ensure strategic governance is coherent across the site, members of the Strategy & Transition Group, of which the IWS team is a part, sit on or chair these various Strategy Steering Groups. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 27 of 61 3.3 Contaminated Land & Site End States 100. The physical condition of the site at the point when the NDA has finished its business is termed the ‘End State’ and the use to which the land is put is termed the ‘End Use’. The West Cumbria Site Stakeholder Group (WCSSG) considered the future of the site, including end state options in 2007 on behalf of the NDA, with the outcome that the preferred end use was continuing industrial and commercial reuse including research. This was influenced by the strong desire for continued significant employment in the local area. There was recognition from the stakeholders that part of the site may remain under long-term institutional control but also an aspiration from the NDA that as much of an “Outer Zone” as possible on the site would be de-licensed. The WCSSG considered this work to be a first stage in an iterative consultation process and expect to be involved in the future evolution of end states. 101. The base case assumption for contaminated land management in the Sellafield 2006 LTP (subject to regulator approval/agreement and demonstration that it was the best practicable environmental option) was that ILW would be excavated and treated to reduce its volume. One proposed means for achieving this would be to concentrate the contaminated fraction of soil in a “soil washing” process, and thus dispose of the contaminant to a national ILW repository. Material that was LLW with activity greater than 37 Bq/g would be disposed of in a near surface disposal facility at Sellafield. Material that was VLLW would be left in place unless excavation was required to gain access to LLW contaminated soil. A programme of local groundwater management would be implemented during the excavation phase to enable excavation of ground from below the current groundwater table. Key assumptions that underpinned the strategy were that: • disposal routes would be available for all the wastes • it would be possible to remove ILW soil from beneath residual building foundations • it would be possible to reduce the volume of ILW by a treatment process • stakeholders, including regulators, would allow VLLW soil to remain in-situ and naturally decay • the site would be under indefinite institutional control and that de-licensing would not be required 102. The 2006 LTP assumed that contaminated ground and groundwater would remain in-situ until 2050 while the Separation Area (the main legacy & nuclear reprocessing zone of site) was being cleared of buildings and facilities, and that remediation would take place between 2050 and 2120. Activities associated with the base case strategy were primarily associated with the restoration phase of the Sellafield site post 2040 and did not identify the need for any interim containment or stabilisation measures to prevent the further spread of contamination prior to completion of decommissioning activities. 103. Since the formation of the new Sellafield Contaminated Land Team this strategy has been under a process of review and the 2007 LTP for contaminated land identified the following key objectives: • Development and implementation of a strategy to manage historical burial trenches in the Separation Area 2008 – 2018. (This is the largest source of radioactivity in the ground) • Management control of existing groundwater contamination 2011 – 2050 • Treatment of existing sources of radioactivity in the ground 2020 – 2050 • Remediation of near surface contaminated ground near or beneath buildings incorporated into the demolition activity (2009 – 2050) 104. These topics are being worked on further, involving regular discussions with the regulators and NDA. The baseline approach now being envisaged is as follows: • Site Characterisation, 2008 -2009 • Assess data, model potential scenarios and carry out BPEO/BPM studies with stakeholder involvement 2010 – 2015 • Institute a groundwater management “line” around the Separation Area, 2015 – 2020 • Remediate contaminated areas around site as they become available, 2020 – 2040 • Remediate Separation Area in Zones between 2040 – 2070 • Consider opportunities to de-license / redevelop / landscape selected areas of the site • Ongoing management of the residual areas, possibly involving waste disposal activities 105. Key elements of the contaminated land strategy are to use the new characterisation data to develop risk based remedial approaches in conjunction with stakeholder and regulatory interaction and to optimise sustainability by effective sorting and segregation of contaminated soil and management of contaminated groundwater in order to maintain control and minimise waste. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 28 of 61 106. The volumes of contaminated land (as currently assessed) remain the same as provided for the 2007 UK Radioactive Waste Inventory, with the assessment providing a range of volumes. Summarised here are the ‘most likely’ volumes of contaminated soil at Sellafield: 3 • ILW Soil, approximately 1,600m 3 • LLW Soil, approximately 1,000,000m 3 • HVVLLW Soil, approximately 13,500,000m 3.4 Integration with Windscale 107. The integration of the Windscale SLC within the Sellafield Ltd SLC took place on 1st April 2008. The NDA and the Environment Agency (EA) recognise that it may take some time to integrate the two sites IWSs; hence for 2008 the two sites IWS reports will be submitted separately. The EA has included within the Compilation of Environment Agency Requirements (CEAR) a requirement for a combined IWS by the end of June 2009. 108. In advance of this, work is being progressed within the financial year 2008/09 to share information and identify opportunities as follows: identify reciprocal opportunities for ILW treatment routes within planned and existing facilities identify and incorporate the relevant data into Sellafield’s Overall Effluent Strategy Model (OESM) for the gaseous and aqueous effluents from the Windscale site sharing 'best practice' between IWS teams following feedback from the NDA review process recently completed by Nexia Solutions 109. This work will form a strong basis for a combined IWS by the end of June 2009. 4.0 Progress Made on Waste Management Strategies 110. The purpose of this section is to report on how different component waste strategies have progressed since the publication of IWS Version 2 in June 2007. The various strategic advances are discussed in terms of the progress made. The aim of which is to provide the reader with an update of the different waste strategies on site, whilst also demonstrating how the principles behind the IWS, such as the waste management hierarchy, are applied. 111. This section should be read in the knowledge of the current funding constraints. The development of most strategic significance for the Sellafield site has been the funding gap. This is the difference between the amount of money Sellafield Ltd will receive from the NDA and the scope of work that was originally planned. As a result a review has taken place and a number of projects have been reprioritised or deferred. The key strategic priority of the site remains focussed on the reduction of the most significant hazards. These are as follows: Reduce Highly Active Liquor (HAL) stocks Retrieve and immobilise Magnox Swarf Silo waste Retrieve and immobilise First Generation Magnox Storage Pond waste Reprocess stocks of wetted Magnox fuel to ensure that fresh Magnox fuel is not allowed to degrade Improve the containment of plutonium residues Reduce the hazard potential of the Floc Storage tanks Retrieve PCM to modern stores © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 29 of 61 112. The format taken for this section is that the different strategies are discussed relevant to their waste form, in that the sub-categories are Solid, Aqueous and Gaseous Wastes. Prior to this, the WMH is explained, and why the Sellafield interpretation varies from the conventional framework. Origin of the Sellafield version of the Waste Management Hierarchy: SAFETY AND RISK REDUCTION AVOID Figure 9 Figure 10 MINIMISE REDUCE RE-USE RECYCLE ENERGY RECOVER ABATE DISPOSE Figure 9 – ‘Conventional’ waste management hierarchy Figure 10 - Sellafield Ltd adjusted version of the Waste Management Hierarchy 113. The WMH is a framework used to inform strategic thinking, highlighting the order in which options for dealing with waste should be considered. The WMH is applied throughout industry, and is not limited to the nuclear sector. The initial aim of the hierarchy was to provide a way of thinking that would extract the maximum possible benefits from products, whilst generating the minimum amount of wastes. Figure 9 is an example of a WMH that would be applied to municipal, non-nuclear, waste management. Figure 10 shows how the WMH has been adjusted to better suit the needs and challenges faced at Sellafield site. As with the traditional model, those at the top of the triangle, shown in green are the factors of most importance, demanding greatest consideration and giving the greatest benefit, and as you progress further down the triangle the options for waste management become less favourable. The primary difference has been the inclusion of ‘safety and risk reduction’, at the very top of the triangle. This is considered the most important priority at Sellafield, such that if a strategic option is chosen which is not necessarily the best from a waste minimisation viewpoint but which provides essential safety & risk reduction, then that strategic option would be considered the ‘right thing to do’. The second difference is the segment that reads ‘Abate’. Prior to waste being discharged into the environment, any opportunity for abatement should be explored. This is predominantly applicable for the treatment of gaseous and aqueous wastes, thus reducing the impact to the environment upon final discharge. Finally, the nature of the Sellafield site inevitably means that a lot of the waste already exists. In such instances the application of the WMH generally focuses on the lower levels of the triangle and on avoiding the unnecessary creation of secondary waste. 4.1 Solid Wastes 4.1.1 Update to the solid radioactive waste strategy 114. The strategy for radioactive solid wastes in this version of the IWS (Version 2) is based on the 2008 LTP strategy for Sellafield. This includes the following changes from the previous (2007 LTP) baseline: Extended Magnox and Thorp reprocessing programmes due to constraints of the HA evaporator capability and the reprocessing strategy for Magnox, overseas & UK Advanced Gas-Cooled Reactor (AGR) fuel. The end of Thorp reprocessing has been extended to 2014/15 (an extension of 3 to 4 years) and Magnox reprocessing to 2015/16 (an extension of 3 to 4 years). The revised end date for HALES (Highly Active Liquor Evaporation and Storage) is now 2024/25 (an extension of 1 to 2 years). © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 30 of 61 There are no major changes from the previous 2007 LTP baseline for LP&LS strategy. Some 2007 LTP opportunities have however progressed into the current 2008 LTP baseline such as processing wet bay ILW from the First Generation Magnox Storage Pond in the Waste Encapsulation Plant (WEP). Further opportunities for LP&LS wastes are currently being developed and will be reviewed through the sites ILW governance process. The high level plan is to retrieve historic wastes from the current storage facilities, immobilise the waste and provide interim storage pending final disposal. The 3 portfolio comprises of approximately 18,000 m of historic waste, which will be immobilised into 24,000 stillages/packages. Handover of the legacy facilities to decommissioning is planned to commence around 2020 and will be completed by 2035. Store operations will be required up until 2070. While there is a desire to accelerate progress, opportunities to reduce the total cost also need to be taken into consideration. The drivers for LP&LS, developed to reflect these concerns are: • Deliver safe, secure and environmentally responsible accelerated hazard reduction • Care for, restore and enhance current assets to allow the ongoing safe storage of the existing inventory so that risks from the inventory are as low as reasonably practicable. • Minimise the creation of new liabilities by making the best use of existing site assets. • In order to achieve risk reduction through the early retrieval and processing of bulk waste and fuel debris the emphasis will be to favour proven, mature technology. However, innovative solutions that are being, or could be, researched and developed to such an extent that they can be expected with confidence to be available within the appropriate period will be considered where these might offer early risk reduction benefits. • Ensure that BPEO process is used to inform the current and future strategy. The strategy for LLW has been revised since the previous 2007 LTP baseline and now includes a suite of new-build treatment facilities (subject to BPEO) so as to minimise overall volumes for disposal to the LLWR and successor facility. These treatment facilities are assumed to commence active operations in 2020 and current arrangements such as High Force Compaction of compactable LLW through WAMAC is expected to continue until this date. After 2020, capability will be available for thermal treatment, melt / smelt and low force compaction. Mechanical decontamination of metals via the site wheelabrator is expected to continue, as is the practice of emplacing any non-compactable (and nonprocessable) LLW into International Standards Organisation (ISO) freight containers for grouting at the LLWR or successor facility. The PCM strategy has been revised since 2007 LTP. The strategy now includes a new build treatment complex to process PCM waste that is not compliant with the current compaction facility (WTC1a). The complex is to commence active operations in 2018 and will include the capability to re-work any PCM that is not suitable for disposal to the repository. Assumptions have also been updated since 2007 LTP and an increased working pattern and throughput rate through WTC1a is assumed in order to contribute towards meeting Nuclear Installations Inspectorate (NII) Licence instrument 326(b). The strategy for the Final Treatment and Disposal of ILW OU has been revised since the previous (2007 LTP) baseline. 2007 LTP assumed mobile facilities for conditioning decommissioning wastes and this concept has now been replaced with facilities that are fixed as there is insufficient industry experience on mobile technology for βγ (beta & gamma) contaminated ILW. The strategy also includes a dedicated facility for inspection, assay and re-work of ILW prior to final disposal. The export of all ILW to the repository including PCM is to remain in the scope of this OU although the rework of PCM is now included in the PCM strategy. There has been no significant change to the VLLW strategy for the site. The lifetime projected volume of VLLW has increased by approximately 22% due to the output from some of the recent decommissioning mandates and bulking factors that were not included in the 2007 LTP assessments. The CLESA is only anticipated to have a 15-20 year lifetime and available capacity and therefore a new facility will be required. This may require new land acquisition and will certainly require planning applications and EA approval. The options for the treatment of High Volume VLLW so as to minimise disposal requirements are included in the IWS option study referred to in Section 2.1, paragraph 42 of this report. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 31 of 61 115. Table 5 illustrates the total lifetime quantity of radioactive wastes requiring disposal from Sellafield and Calder Hall, including reconciliation against the previous baseline. Table 5 – Total lifetime projection of packaged waste from Sellafield (excluding LLW and VLLW contaminated land) Waste 2007 LTP 2008 LTP Explanation for the Category packaged packaged difference 3 3 volume (m ) volume (m ) 1,565 m3 = 8,070 1,464 m3 = 7,545 Reduction HLW in AGR fuel HLW containers HLW containers reprocessed due to the shut *excludes returns *excludes returns down of Thorp as well a to overseas to overseas reduction in HLW projected customers customers from POCO 3 279,450 m3 218,644 m ILW Decommissioning arisings 3 3 = 63,375 3m box = 81,000 3m box have increased due to the (inc. equivalents equivalents output from some of the PCM) completed mandates as well as revised loading assumptions 3 for 3m boxes. 3 3 830,817 m 755,566 m LLW Although raw waste quantities = 42,606 HHISOs = 38,747 HHISOs have increased due to the output from decommissioning mandates, overall packaged volumes have reduced due to the impact of the new LLW treatment processes assumed in 2008 LTP 3 3 1,153,000 m 1,407,767 m Raw waste quantities have VLLW (Raw waste) (Raw waste) increased from decommissioning due to the output from the completed decommissioning mandates and bulking factors that were not included in 2007 LTP assessments. 116. It should be noted that the Waste Accountancy Templates required by the NDA have superseded the waste inventory information previously provided in the June 2007 IWS (Version 2). 4.1.2 High Level Waste (HLW) strategy 117. The HLW strategy has been updated since the previous issue of the IWS (June 2007) and reflects the extended Magnox and Thorp reprocessing programmes. New build is required for additional HA evaporator capacity, replacement Highly Active Storage Tanks (HASTs) and a replacement Vitrified Product Store (VPS). 118. The extended outage of Thorp as a result of the feed clarification cell event has impacted on the NII’s position on HAL stocks. The headroom between the current inventory and the NII limit is greater than envisaged at the time the specification was issued and consequently the NII have changed the shape of the specification as part of its biennial review in 2007. 119. The total allowable stocks of HAL are to be progressively reduced until July 2015 when the stock of HAL is 3 less than 200m . Reductions are to be achieved through management of reprocessing and vitrification schedules. Figure 11 illustrates the predicted levels of HAL stocks compare with the limits as established with the NII, shown by the teal coloured trace. It can be seen that the total volume within the HAST tanks is always below the agreed limit. Key assumptions within Figure 11 include the routing of fresh HAL arisings to replacements HASTs from 2013, throughputs between 300-400 containers per annum through Waste Vitrification Plant (WVP) for the remainder of the vitrification programme and no inclusion of wash liquors. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 32 of 61 Figure 11 - Levels of acceptable HAL stocks as agreed with the NII Graph comparing volume of Highly Active Liquor (HAL) with the NII agreed limit for HAL stocks 1400 1200 Volume (m3) 1000 800 600 400 200 0 Apr-2008 Apr-2009 Buffer Volume 120. Apr-2010 Apr-2011 HAST Tanks No. 9-21 Apr-2012 Total HAST Tanks Apr-2013 Total HAL Limit Apr-2014 Apr-2015 Total HAST inc. wash water The strategy associated with the lifespan of the HLW evaporators (A, B, C, D and E) have been revised since the previous 2007 LTP baseline as follows: Evaporator A: To support WVP returns only, until 2020 Evaporator B: To support 90% Magnox operations until Financial Year (FY) 2010/11 and then remain available as a contingency until 2012/13 Evaporator C: To support 10% Magnox and 100% Thorp operations until FY 2010/11 and then remain available as a contingency until 2013/14 Evaporator D (new build) : To support all Magnox and Thorp operations and POCO from 2010/11 and remain available as a contingency until 2022/23 Evaporator E (new build): To support WVP effluent arisings from 2010/11 and POCO of the HASTs until 2024/25 It should be noted for Evaporators D & E that these timescales are under review by ourselves, the NDA, and the project contractors - taking into account the capability within the UK and worldwide to deliver such major engineering projects. Extending these timescales has a significant impact on extending the operational life and delaying the decommissioning programmes of the HLWPs and downstream plants and infrastructure. 121. Provision has been made in 2008 LTP for additional HAST capacity due to risks associated with the long term capability of the current HAST fleet to support ongoing reprocessing, WVP operations and POCO. The issues are primarily due to corrosion of cooling components and there is ongoing work to establish the full mitigation of this as well as final HAST capacity requirements. 122. The Residue Export Facility (REF) is undergoing commissioning after recent modifications. The aim is to enable Vitrified Residue (VR) to be returned to overseas customers. The facility will enable the VR containers in the Vitrified Product Store (VPS) to be de-stored, checked for customer acceptability and then loaded into export flasks. Exports are assumed to commence this year in Financial Year 2008/09 and are scheduled to be completed by end of 2015/16. A total of 1,787 containers are assumed to be exported. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 33 of 61 123. An additional Vitrified Product Store (VPS2) has been included in 2008 LTP due to the 50 year design life constraint on the existing VPS (VPS1). VPS 1 is expected to reach its design life-limit by 2040 and VPS 2 will therefore ensure sufficient capability to safely store vitrified containers until the availability of the repository, currently assumed to be 2075. Export of vitrified containers to the repository is expected to be completed by 2095 as illustrated Figure 12: VPS (WVP Containers Stored profile) VPS Capacity (7960) 8000 7000 Number of Containers Stored WVP Containers 6000 5000 4000 3000 2000 1000 Mar 2099 Mar 2096 Mar 2093 Mar 2090 Mar 2087 Mar 2084 Mar 2081 Mar 2078 Mar 2075 Mar 2072 Mar 2069 Mar 2066 Mar 2063 Mar 2060 Mar 2057 Mar 2054 Mar 2051 Mar 2048 Mar 2045 Mar 2042 Mar 2039 Mar 2036 Mar 2033 Mar 2030 Mar 2027 Mar 2024 Mar 2021 Mar 2018 Mar 2015 Mar 2012 Mar 2009 0 FY Ending Figure 12 - WVP containers requiring storage and disposal - minus exports to overseas customers 4.1.3 Intermediate-Level Waste Strategy Update 4.1.3.1 Operational wastes 124. The Magnox and Thorp reprocessing programmes have been extended which has resulted in an increase to the operating timescales for the supporting ILW conditioning facilities, namely Magnox Encapsulation Plant (MEP) and Waste Encapsulation Plant (WEP). The Waste Packaging and Encapsulation Plant (WPEP) will also continue to support reprocessing and remediation activities. 125. MEP will continue to support Magnox decanning operations and POCO until 2019/20. Once Magnox reprocessing has been completed, there are potential opportunities for utilising MEP to condition other ILW such as Tokai Mura End Crops, Magnox Silo scrap and some βγ contaminated ILW from decommissioning. These opportunities are to be reviewed through the ILW site governance processes. 126. WEP will continue to support Thorp reprocessing which is currently scheduled until 2014/15. It will also condition Magnox Ponds Wet bay miscellaneous solid wastes from 2010 onwards and is likely to continue to do so until the availability of the Box Encapsulation Plant (BEP), currently planned to become operational in 2015. There is also an opportunity to utilise WEP for other ILW waste and these opportunities are to be reviewed through the site ILW governance processes. 127. WPEP will continue to support reprocessing of bulk feeds from Thorp and Magnox and condition active flocculates generated from the EARP. The baseline now includes the diversion of SETP feeds to EARP subject to continuing technical underpinning. Further opportunities for utilising WPEP are to be reviewed through the site ILW governance processes. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 34 of 61 4.1.3.2 Legacy Ponds and Legacy Silo wastes 128. The overall strategy for LP&LS has not changed significantly from 2007 LTP. The primary driver for the LP&LS areas is still the early hazard and environmental risk reduction for the facilities and commitment to meet the licence specifications issued by the NII on 04 August 2000. 129. The treatment facilities planned within the LP&LS strategy are as follows: Silos Direct Encapsulation Plant (SDP) - For the conditioning of ILW from Magnox Swarf Storage Silos. This facility is assumed to be operational from 2013 to 2027 Sludge Packaging Plant (SPP1) - For the conditioning of ILW sludges from the First Generation Magnox Storage Pond. This facility is assumed to be operational from 2017 to 2022 Local Sludge Treatment Plant (LSTP) for the conditioning of ILW sludges from the Pile Fuel Storage Pond. This facility is assumed to be operational from 2015 to 2021 BEP - For the conditioning of ILW solids from the First Generation Magnox Storage Pond and the Pile Fuel Storage Pond. This facility is assumed to be operational from 2015 to 2024 Pile Fuel Cladding Silo Treatment Plant (PFSTP) - For the conditioning of ILW from the Pile Fuel Cladding Silo. This facility is assumed to be operational from 2022 to 2026 SIXEP Waste Processing Plant (SWP) - For the conditioning of SIXEP sludges and Sand / Clino. This facility is assumed to be operational from 2013 to 2019 130. Conditioned LP&LS ILW packages are to be stored in the suite of new-build Containerised ILW Stores (CILWS) until 2040 (date given by the NDA for the availability of the ILW repository). The Encapsulated Product Store 3 (EPS3) is to store some conditioned ILW from SDP prior to CILWS being available. 131. The potential re-work and export of ILW is included within the LTP Final Disposal and Treatment of ILW OU and the strategy for this is detailed in the latter part of Section 4.1.3.4 of this report. 4.1.3.3 PCM wastes 132. The PCM strategy has been revised since the previous baseline to include an additional PCM treatment complex in order to condition wastes that are not suitable for processing through WTC1a and to assist in meeting the regulatory specification of NII Licence Instrument 326(b). The new build complex is assumed to commence active operations in 2018 and will continue operating until the end of PCM arisings, currently projected to be circa 2060. 133. Operation of the current PCM treatment facility (WTC1a) is scheduled to continue until 2023 with progressive enhancements to its throughput deriving from improvement projects and a stage-wise step change from the 5 day double day working pattern to 7 day double days in 2010 and 7 day 3 shift from 2015 until 2023. This, alongside with the new PCM treatment complex, is assumed to achieve conditioning of the historic PCM referred to in the NII Licence Instrument, Li326(b), by August 2020. 134. Raw and conditioned PCM wastes are interim stored in the Engineered Drum Stores (EDS’s). EDS 1 and 2 are operationally full, EDS 3 is operation but its capacity is limited until appropriately designed drum stillages have been procured to allow optimum use of the storage volume. Modelling work has indicated, a small store 4 could be required around 2018 based on current Sellafield waste projections. Opportunities to improve working efficiencies are being explored so that this store will not be required. 135. The new build PCM treatment complex is to also include the capability to re-work any out of specification waste products to meet the Repository Waste Acceptance Criteria. The export of PCM product to the Repository is included in the LTP OU Strategy – Final Treatment and Disposal of ILW. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 35 of 61 4.1.3.4 136. Final Treatment and Disposal of ILW The strategy for the Final Treatment and Disposal of ILW includes the following scope: Treatment and conditioning of βγ ILW from decommissioning, MBGWS contents, AGR dismantler wastes and excavated contaminated land. Potential rework of any βγ ILW waste products as required in order to satisfy the Repository Waste Acceptance Criteria Vouchsafing and exporting the lifetime yield of βγ ILW and PCM products to the repository 137. The strategy has been revised to include three new-build ‘fixed’ waste treatment facilities as opposed to ‘mobiles’ which were assumed in the previous baseline. The removal of mobiles as a concept is due to a lack of evidence in the industry for demonstrating the practicability of large-capacity, mobile ILW treatment plants – particularly with regards to high dose-rate materials anticipated to arise from Sellafield decommissioning activities. 138. There is an opportunity to offset the additional liability of the new treatment facilities by utilising the remnant life of the existing and future committed ILW treatment facilities (e.g. WEP, BEP, SDP etc). This opportunity is being explored further and will be reviewed through the site ILW governance process. 139. A dedicated new-build βγ ILW product inspection and re-work facility has also been included in the baseline strategy. This facility is scheduled to commence active operations from 2035 (approx. 5 years prior to repository availability) until the end of Sellafield ILW exports to the repository, currently projected to be 2108. 140. The rate at which ILW is to be exported to the repository is currently being reviewed by the NDA as part of its ongoing National Repository Scheduling exercise. Until this work is finalised, Sellafield has received guidance from the NDA to assume an export rate of around 1,200 ILW packages per annum for the 2008 LTP. It should be noted that this constraint requires the site to export ILW over a lengthy period of 60 years and significantly challenges the design lives of the existing stores. Work is currently ongoing to optimise the store design lives as well as the export rate to the repository. 141. Figure 13 illustrates the total ILW Export profile from Sellafield to the repository. Key assumptions have been made in deriving the profile such prioritising the export of ILW from older stores in order to minimise the impact on the store lifetimes. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 36 of 61 OU35240 - Export Profile to ILW Repository after Rework/ Final Conditioning 1,400 1,200 Ground Box/Stillage Equivalents 1,000 ILW from Decommissioning. 800 Class 2(A) EPS3 600 CILWS1 CILWS2 CILWS3 CILWS4 Class 2(A) Ext. EPS2 EPS1 400 200 AGR Dismantler Stores WPEPS MBGWS EDS2 EDS3 EDS4 20 40 20 42 20 44 20 46 20 48 20 50 20 52 20 54 20 56 20 58 20 60 20 62 20 64 20 66 20 68 20 70 20 72 20 74 20 76 20 78 20 80 20 82 20 84 20 86 20 88 20 90 20 92 20 94 20 96 20 98 21 00 21 02 21 04 21 06 21 08 0 Financial Year Start Figure 13 - Export profile of all ILW (including PCM) from Sellafield stores to the Repository 4.1.4 Low Level Waste strategy 142. The LLW OU is developing the site’s LLW Strategy for issue in January 2009. The strategy will be informed by the recent series of public workshops that covered such LLW as oils, metals, process waste, etc. 143. The LLW strategy, as described in 2007 LTP, has since been updated and now includes a suite of new build treatment facilities, these are all assumed to commence operations in 2020. The facilities are to provide a greater degree of volume reduction than that which currently exists on the site and hence will minimise the overall quantities for disposal to the LLWR or successor facility. The LLW strategy is summarised below: Continued use of WAMAC for high force compaction of compactable LLW until 2020 New build thermal treatment capability from 2020 up to the end of site decommissioning, currently scheduled to be 2113 New build melt / smelt capability for LLW metals from 2020 up to 2113 New build low-force compaction capability for compactable LLW from 2020 up to 2113 Continued use of mechanical decontamination in the form of the wheelabrator for the decontamination of metals up to 2113 Continued use of direct emplacement of non-compactable items into ISO freight containers Disposal of LLW to the LLWR until 2050 and to a future LLW disposal facility that has not yet been specified 144. Processing assumptions such as the proportion of waste that are suitable for various processes and the resultant volume reduction achieved are include in the 2008 LTP poster set. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 37 of 61 145. The total quantity of LLW requiring disposal over the lifetime of the site is illustrated in Figure 14 below. A comparison is made between the 2008 LTP strategy and the 2007 LTP strategy with the same (2008 LTP) data-set and it can be seen that the suite of 2008 LTP treatment facilities contribute towards a reduction of around 19,300 HHISOs. Work is ongoing to understand the range of uncertainty on the waste estimates as well as the cost and environmental benefit of the new treatment facilities. 70000 2,600 Continue processing as-is Metal Ingots Metal unsuitable for melting Concrete LTP 07 capability 2,400 60000 2,200 2,000 Overall reduction of 19,300 HHISO's Number of HHISO's 1,800 1,600 50000 LTP 08 capability 40000 1,400 1,200 30000 1,000 800 20000 600 400 10000 200 0 20 07 20 /08 11 20 /12 15 20 /16 19 20 /20 23 20 /24 27 20 /28 31 20 /32 35 20 /36 39 20 /40 43 20 /44 47 20 /48 51 20 /52 55 20 /56 59 20 /60 63 20 /64 67 20 /68 71 20 /72 75 20 /76 79 20 /80 83 20 /84 87 20 /88 91 20 /92 95 20 /96 99 21 /00 03 21 /04 07 21 /08 11 21 /12 15 21 /16 19 /2 0 0 Year of Disposal Figure 14 – 2008 LTP LLW Lifetime Disposal Profile 146. There are opportunities to further minimise waste volumes such as by increasing the decontamination capability on the site and appropriate volume reduction of concrete items to increase packing efficiency. 147. The NDA have instructed the LLWR to develop a strategy for the management and disposal of the nation’s LLW. The key decisions relating to national LLW matters are made by the NDA and the LLWR. The current planning assumption used by Sellafield Ltd is for continued availability of the LLWR for accepting LLW (detailed in Section 4.5.3 of IWS Version 2). Sellafield Ltd also has risk mitigation measures should the LLWR become unable to accept LLW from Sellafield Ltd. 148. The NDA initiated a competition process in April 2006 for a new PBO to run the LLWR site, including ownership of the LLW Repository Limited Company. The new PBO has a broader remit than the previous operators – it is responsible for the co-ordination of LLW management activities and any potential new facilities throughout the UK. 149. In the autumn of 2007 NDA announced that UK Nuclear Waste Management Ltd (UKNWM Ltd) was the ‘Preferred Bidder’ for the LLW Repository contract. UKNWM is a consortium led by Washington Group International with Studsvik UK, Serco and Areva. The new PBO took over responsibility for the LLW Repository Site from BNFL on 1st April 2008. 150. LLW Repository Ltd is working in partnership with the NDA to establish the National Low Level Waste Strategy Group (LSG) to develop and implement a National LLW Strategy. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 38 of 61 151. The National LSG has been established to develop a working partnership between the NDA, LLW Repository Ltd, Regulators, Stakeholders and LLW Consignors to promote innovation, value for money, and implementation of the waste hierarchy by planning for effective waste disposal solutions. This initiative will support ongoing nuclear operations, the nuclear site decommissioning and remediation programme and LLW management needs of ‘non-NDA’ commercial organisations. The National LSG shall serve as a primary point of contact for integration and engagement on LLW innovations, issues, and strategy development. 152. Sellafield Ltd is already anticipating this work and is responding to this National LSG via the current work towards producing a LLW strategy for the Sellafield site by January 2009. As Sellafield waste is expected to comprise more than half of all the LLW in the UK, the Sellafield LLW Strategy is likely to form the central basis of the UK LLW strategy. 4.2 Aqueous Waste Strategy 153. This section represents the update to the Aqueous Waste Strategy (AWS) as required under Schedule 9 Requirement 1 of the RSA 93 Authorisation within the ‘Compilation of Environment Agency Requirements’. Historic and Current Aqueous Waste Strategy 154. To understand the origins of the current AWS for Sellafield site it is necessary to examine the strategy for liquid effluents developed and implemented in the 1980s. This is summarised below: “Following the November 1983 beach contamination incident, BNFL made a public commitment to study what technical options could be employed to reduce low level liquid waste (LLLW) discharges to the sea. The specific objectives are to reduce the alpha and beta-gamma discharges to target levels of 0.74 TBq/yr (20 Ci/yr) and 296 TBq/yr (8000 Ci/yr) respectively and to prevent the discharge of solids and free-phase solvent. SCOPE Objectives Initial scoping work carried out during 1985 was formally reviewed by the Effluent Task Force during 1986, with a remit to ensure that whilst meeting all the functional requirements, the scope of work and cost of the proposed development were minimised. The specific objectives to be achieved are as follows: (i) To reduce alpha and beta discharges in accordance with the discharge authorisation requirement that ‘the best practicable means should be used to keep discharges as low as reasonably practicable’. In this regard, nominal design targets of 0.74 TBq/yr (20 Ci/yr) alpha and 296 TBq/yr (8000 Ci/yr) beta have been supported by the Radioactive Waste Management Advisory Committee (RWMAC) and the Department of Environment (DoE). (ii) To prevent the discharge of free-phase solvents and suspended solids.” © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 39 of 61 155. Since the articulation of the original strategy in the mid to late 80s the plants and infrastructure has now been built and operated successfully to maturity and generally met or exceeded design intent. This strategy was developed and deployed by the suite of plants depicted diagrammatically in figure 15 below: 156. Figure 15 – Sellafield effluent treatment plans 1987 Summary of New Effluent Treatment Plants for the Sellafield Site (1987) Pond Purges Site Ion Exchange Effluent Plant Low Risk Effluents Effluent Treatment Plant Sea Tanks 1, 2 & 3 Recycle Segregated Effluent Treatment Plant Medium Active Concentrates Sentencing in SETP Off Spec Pumping System Medium Active Tank Farm Magnox Spent Solvent Thorp Spent Solvent Salt Concentrate Solvent Treatment Plant Waste Packaging Encapsulation Plant Highly Active Tank Farm Recycle Enhanced Active Removal Plant Magnox High Risk Effluents Analytical Services Low Risk Effluents Analytical Services High Risk Effluents Sentencing in EARP Break Pressure Tank SEA Sentencing in Analytical Services Treatment in Analytical Services Preliminary Sentencing in Analytical Services Thorp Multielement Bottle Flushings Thorp Central Off-gas Sentencing in Thorp Thorp Dissolver Off-Gas Effluent Plant Services Building Effluent Plant Maintenance Facility Key Concentrates Solvent Low Risk Effluents High Risk Effluents Sea Discharges Solids 157. Updated descriptions: Original Diagram by M Howden Aug 1987 Drawn by C G Howarth Figure No A1 This strategy forms the basis by which the site currently manages its effluents and is manifested in the following tactics: • Plants and processes will use BPM to minimise the quantity, activity and suspended solids content of liquid effluent arisings, and to segregate different categories of liquid effluent • Plants and processes will generally discharge their liquid effluents to centralised treatment facilities, complying with any receiving plant acceptance criteria • Centralised effluent treatment plants will continue to be operated as long as technically feasible and safe to do so. Technical feasibility takes account of economically viable asset care and changes to effluent feed quality and quantity. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 40 of 61 • Magnox and AGR fuel pond and Magnox silo effluents are generally discharged to SIXEP for the removal of Magnox sludge, other suspended solids and soluble caesium and strontium, prior to sea discharge HA effluents and low salt medium active effluents are evaporated to minimise volume and immobilised by vitrification High salt medium active effluents are evaporated to minimise volume and delay stored to reduce short lived beta emitters. They are then subjected to floc precipitation and ultrafiltration to reduce activity prior to sea discharge High alpha, low active effluents are subjected to floc precipitation and ultrafiltration to reduce activity prior to sea discharge Low active acidic effluents are neutralised and blended with low active caustic effluents prior to sea discharge Thorp Dissolver Off-Gas scrubber effluent is treated locally by C-14 precipitation and decanting prior to sea discharge Thorp pond purge is filtered locally to remove suspended solids prior to sea discharge. Long lived I-129 is driven to sea as this has been identified as BPEO • • • • • • • • The original strategy is still valid but there have been a small number of improvements in implementation resulting from subsequent BPM assessments. An example of this is the diversion of Magnox Medium Active Concentrate (MAC) to the HLWPs for vitrification instead of decay storage and treatment in EARP prior to discharge to sea. This has significantly reduced the amount of Tc-99 discharged to sea, which primarily yields socio-economic benefit. It was made practicable by internal segregation of minor, incompatible components, and by the recommissioning of an existing route. Further improvements may be identified from ongoing consideration of BPM for current operations and from BPEO/BPM assessments for facilities at various stages of design • It is interesting to compare the original nominal design targets of 0.74 TBq/yr (20 Ci/yr) alpha and 296 TBq/yr (8000 Ci/yr) beta against the discharge authorisation limits of that time. When the new effluent systems became operational (and looking forward to Thorp being operational), authorised discharge limits were set at 1 TBq/yr alpha and 400 TBq/yr beta. A significant portion of the total beta limit was to enable the processing of historic MAC stocks, which has been completed. Historical & M odel Predicted Discharges - Beta-5 Discharges Historical & Model Predicted Discharges - Alpha Discharges 250 12000 1970's authorisation 1970's authorisation 10000 Historical Discharges OES Predicted Discharges Authorised limit 150 100 Historical Discharges OES Predicted Discharges Authorised limit 8000 Activity, TBq A ctiv ity , TBq 200 6000 1986 MAFF authorisation 4000 1986 MAFF authorisation 1990 MAFF authorisation 1990 MAFF authorisation 50 1994 RSA93 authorisation (unchanged by SALDAR) 2000 2004 revised RSA93 authorisation 1994 RSA93 authorisation (unchanged by SALDAR and SALDAR2) 09 20 05 07 03 20 20 20 01 99 19 20 95 97 19 91 93 19 19 19 87 89 85 19 19 19 83 81 19 19 77 79 19 73 75 19 19 19 19 07 09 05 Date 20 20 20 01 99 03 20 20 19 95 93 91 89 87 85 97 19 19 19 19 19 19 19 81 79 83 19 19 19 75 73 77 19 19 19 19 71 0 71 0 Date Figure 16 – Comparison between historical and model predicted discharges 158. Sellafield operates its current AWS in a manner consistent with the original intent though enhanced with appropriate tactics, in line with developing regulatory requirements and complying with the discharge authorisation of the day. 159. Plants and systems where aqueous wastes are generated, processed or disposed of are managed, operated and maintained by suitably qualified and experienced persons in accordance with written processes and procedures. Sellafield Ltd operates under environmental and quality management systems which are externally validated to appropriate international standards (BS EN ISO 14001: 2004 and BS EN ISO 9001: 2000). © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 41 of 61 This is supported by the findings of a recent comprehensive review by R M Consultants which stated • “The outcome of this comprehensive review demonstrates that Sellafield Ltd’s minimisation practices for airborne, liquid and solid radioactive wastes are mainly consistent with those recognised as BPM or best practice in comparable national and international situations. • The fact that there are only a few areas found for improvement is a good indication of the efficiency and effectiveness of the overall site waste management system and its integration across the site. • For the Sellafield site, identifying ‘best practice’ for the full range of waste streams is a taxing task, as many of the processes are specially commissioned operations …Sellafield has necessarily led the way and can by default be regarded as developing and demonstrating use of best practice. • The exception is for some electrochemical separation technologies including electroflocculation (used by Atomic Weapons Establishment, (AWE)) and electrochemical ion-exchange (used by GE Healthcare and United Kingdom Atomic Energy Authority (UKAEA)). These techniques are not used by Sellafield Ltd due to the large volumes of liquid effluent processed, which would cause the electrochemical process to be too expensive.” Future Aqueous Waste Strategy 160. There are residual uncertainties that will exist as the Sellafield site moves from a well understood operations role to a decommissioning and clean up role. Decommissioning and clean-up of the site will not only involve the current operational facilities but also the legacy facilities which contain radioactive wastes from the early days of civil and military operations at the site. In this period of change it is important that strategic aspects are managed so as to prevent and minimise future environmental impacts. A number of facilities will have significantly different challenges during the transition from production to clean up. Whilst this presents some risks as a result of changing flowsheet there may also be opportunities to re-route streams, improve environmental performance and reduce costs via employing different tactics to achieve BPM. 161. It is worth noting that a contributing factor in determining that the MAC diversion represented BPM was because it could be implemented via an existing route (which meant costs were not disproportionately large in relation to the environmental benefits realised). However, even this was not straightforward: as a result of changing the flowsheet there were knock-on implications for the final solid waste forms which must always be weighed up in the site’s considerations of the balance of waste forms and Engineered Destinations (the reader is referred to the 2007 IWS - Version 2 for a more detailed explanation of these concepts). 162. In continuing to develop the future AWS for the site, it must be recognised that appropriate use of available public money requires Sellafield Ltd to prioritise its focus on those areas where the maximum value and benefit in terms of hazard and environmental risk reduction can be achieved, subject to complying with legal requirements. 163. Today significant areas of potential environmental risk are associated with the Magnox Operating Plan (MOP) and legacy remediation. In the current environment of constrained funding the greatest environmental benefit will be obtained by investing in these areas i.e. improving MOP timescales and progressing remediation of high risk facilities, rather than diverting limited funds and key resource towards the marginal benefits in the area of effluent abatement. 164. Investment in order to realise marginal benefits can prove to be disproportionate and would be difficult to justify on BPM grounds. This is particularly so where the implementation time is significant and benefits can only be realised for a short time. All investment proposals are subject to a rigorous challenge processes intended to expose the costs and benefits so that an informed decision may be taken by Sellafield Ltd and NDA as necessary. 165. Work on the long term approach to effluent management at Sellafield was undertaken as part of the Overall Effluent Strategy (OES), beginning in 2004. The original aim of the OES was to determine the optimum processes and chronology for liquid effluent management during the site clean-up programme, balancing all stakeholder constraints and expectations in compliance with the UK Discharge Strategy. The OES work was focussed on the timeframe beyond completion of the MOP and the bulk waste retrievals of LP&LS. The Aqueous Waste Strategy Steering Group was established in 2005 with a remit of governance on Site effluent management and an initial focus on current effluent issues. The work of the OES team and © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 42 of 61 the (now) Aqueous & Gaseous Waste Strategy Steering Group (AGWSG) is consistent, and the output is embedded into the LTP. Furthermore the modelling and tools that are used cover the full lifetime of the site and have identified opportunities in both the short and longer term. Decisions on aqueous waste strategy for the current and medium term are thus taken with reference to the longer term strategy (OES). 166. The OES work is also relevant to the IWS. Decisions by the IWSSG are taken with due regard to the OES work. The aqueous waste strategy is focused upon optimising the use of existing facilities, supported by additional facilities only when required. 167. The aims of the UK Discharge Strategy are: • progressive and substantial reduction of radioactive discharges and discharge limits, to achieve the strategy targets for each sector; • progressive reduction of human exposure to ionising radiation arising from radioactive discharges, as a consequence of reductions in discharges, such that a representative member of a critical group of the general public will be exposed to an estimated mean dose of no more than 0.02 mSv a year from liquid radioactive discharges to the marine environment made from 2020 onwards; • progressive reduction of concentrations of radionuclides in the marine environment resulting from radioactive discharges, such that by 2020 they add close to zero to historic levels. (The terms “close 6 to zero” and “historic levels” are not defined in the OSPAR Strategy and the OSPAR Commission is continuing to work on establishing agreed definitions.) Strategic targets for spent fuel reprocessing are stated to be: • • • • Reduce the estimated dose to a representative member of the critical group of the general public (i.e. those persons most exposed to the discharge) to be less than 0.02 millisieverts (mSv) per annum as a consequence of reductions in discharges to the marine environment from 2020 onwards. By 2020, total Beta aqueous discharges from reprocessing to be reduced to around 50 TBq/yr Beta 5 (excluding Tritium) By 2020, total alpha aqueous discharges from reprocessing to be reduced to around 0.2TBq/yr By 2006, Tc99 aqueous discharge from reprocessing to be reduced to less than 10TBq/yr, and by 2020 to less than 1TBq/yr 168. To meet these aims, and deliver an optimised strategy regarding aqueous waste, the OES team has looked to incorporate national and international best practice for effluent management. Alignment of the OES to the UK Discharge Strategy was achieved in June 2007 and it was predicted future discharges would be below the current RSA (93) Authorisation site discharge limits. 169. When treating aqueous streams, an emphasis is placed on abatement as the consideration of applying BPM to Avoid, Minimise, Reuse & Recycle has already taken place in the selection of process design and operation of the generating plants. The aim of the abatement step is to transfer the activity from a liquid to a solid form and contain it for disposal, thus immobilising the activity. It is worth noting that the “Avoid” step has been assessed by the OES team. They have successfully identified several opportunities to “Avoid” building new treatment plants and hence avoid adding to the decommissioning legacy through optimising the use of existing aqueous waste treatment assets such as SIXEP and EARP. 170. The Sellafield site has recently set in place strategic governance arrangements to develop the site’s AWS beyond the baseline described in IWS Version 2. The AGWSG was founded in 2005 to provide oversight of effluent development to ensure it does not compromise the existing baseline strategy and to develop it further. Using the output of the OES, the IWS, together with OU developments and the site’s response to the recent EA enforcement notices on particulates, the progress in developing the AWS further has been in the following 4 main areas. The Particulate Enforcement Notice served by the EA The management of aqueous waste that arises from the waste retrievals and treatment programmes in LP&LS, SIXEP and the historic floc storage tanks. 6 The 1992 OSPAR (Oslo & Paris) Convention is the current instrument guiding international cooperation on the protection of the marine environment of the North-East Atlantic. It combined and updated the 1972 Oslo Convention on dumping waste at sea and the 1974 Paris Convention on land-based sources of marine pollution. The work under the convention is managed by the OSPAR Commission representing the European Community. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 43 of 61 The proposal to switch feeds from SETP to EARP Bulks once volumetric flows decrease following the end of reprocessing operations. The developing strategy for managing the future requirement for Low Active Effluent collection, treatment, and disposal beyond the existing centralised facilities (i.e. after 2040). 171. These are discussed in more detail in the sections below 4.2.1 Sellafield Ltd’s response to the Particulate Enforcement Notice 172. In May 2007 the EA issued the Enforcement Notice (EN) No. RS/E NW 000832 to Sellafield Ltd regarding concerns over the potential for active particulates to be discharged from site and thus enter the surrounding environment. The basis for this concern is that a number of active particles have been discovered on beaches local to Sellafield during monitoring programmes. The enforcement notice specified the following: 173. 1. The Operator shall carry out a best practicable means study into the removal of entrained solids from radioactive aqueous waste prior to discharge to the environment 174. 2. Implement recommendations identified in 1 above to a schedule and programme agreed in writing with the Agency or failing agreement, as reasonably specified in writing by the Agency. 175. In accordance with the specification, Sellafield Ltd prepared and submitted a response report to the Agency at the end of March 2008, together with a proposed programme of future work. The development of the forward programme includes the continuation of work that has already commenced and also captures new work. This work can broadly be categorised into the following: 176. 1. A continued programme of sampling and analysis to inform ongoing and future decisions; 2. Completion of the BPM reviews and any necessary action to address plant specific issues; 3. Ongoing work to address generic site-wide issues including Standards and best practice guides; 4. The development of a specific project looking at solids exclusion from the Sellafield sealine discharges. 4.2.2 Legacy Ponds & Legacy Silos – SIXEP Contingency Plan 177. The SIXEP became operational in 1985 and treats the high volume, low specific activity (number of disintegrations per unit of time), alkaline liquid effluents at Sellafield site. These are generally purge effluents from fuel cooling ponds. SIXEP filters the effluents to remove solids and subsequently uses ion exchange technology to target the removal of soluble Cs-137 and Sr-90 prior to monitoring and sea discharge. 178. The SIXEP Operating Plan (SixOP) for the period 2007 to 2042 revises and updates the SIXEP Operating Strategy (SixOS), which was relevant to 2022. It describes the progress that has been made to improve plant performance and to maintain the plant in a suitable condition to meet future lifetime requirements. 179. A prime objective of SixOP is to ensure that the Site Executive has an understanding of the complex issues and uncertainties that exist regarding: The demand on SIXEP from current and future donor plants e.g. the effects of extended production and remediation programmes, and the increased challenge from remediation activities particularly of Sr-90 derived from sludge in the first generation Magnox storage pond. The capability of SIXEP to provide a high level of service with respect to solid waste storage, plant longevity and availability. The environmental impact from the application of BPM improvements to the abatement of discharges to sea from high volume, low specific activity, alkaline liquid effluents as the site moves progressively from production operations into its clean-up phase. The provision of short/medium term and long-term contingency plans in the event of a failure of SIXEP. 180. Ensuring that the Site Executive has an understanding of the issues means that a credible strategy can be endorsement, meeting the requirements of: The MOP and Nuclear Decommissioning & Major Projects Group (ND&MPG) needs i.e. existing and future donor plants. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 44 of 61 BPEO and BPM principles. The provision of contingency measures for the site. Discharge authorisation compliance. 181. Development of this plan has included: Business and stakeholder needs. Consideration of the current and known potential future feeds. An assessment of the longevity of SIXEP giving due recognition to the current age and expected operating life of the plant. A review of current and future liquid feeds to determine how the challenge can be met in relation to the existing discharge authorisation. Tank capacity in relation to the management of the waste solids produced by SIXEP. A BPEO study to evaluate all strategic options that are available for the management of low specific activity, high volume, alkaline liquid effluent streams. A review of asset care and risk management strategies. A review of plant enhancement and new build projects that were suggested in SixOS. Establishing contingency principles for managing short to medium term plant outages. Proposals for a SIXEP contingency plan that includes long-term provision of alternative capacity. 182. The four composite recommendations are therefore as follows: Enhance the robustness and performance of SIXEP through a programme of asset care and specific plant based improvements. Improve the ability of SIXEP to manage future feed challenges through the completion of critical technical work packages. Optimise existing storage capacity for sand and spent ion exchange media, and ensure that adequate retrieval programmes are in place. Deploy Bulk Storage Tank 13 (BST13) when the Medium Active Solid Waste Encapsulation Plant (MASWEP) tank ‘A’ and BST 14 are full. Do not commission MASWEP tank ‘B’ unless it is needed to store an alternative ion exchange medium. Deliver an operational SIXEP Waste Retrievals (SWR) / Sludge Packaging Plant 2 (SPP2) by 2016 to ensure compliance with NII Licence specification 326. Develop and implement a comprehensive SIXEP contingency plan, considering donor plant management, asset care and new-build options. 4.2.3 Switching feeds from the Segregated Effluent Treatment Plant to the Enhanced Actinide Removal Plant. 183. The Sellafield “Gate C” Strategy, issued in March 2006, contained an OES which identified that the volume of low active effluent arisings remaining after reprocessing operations cease is inadequate (too low) to enable one of the effluent treatment plants that deals with low activity, high risk effluents (EARP Bulks) to continue its current operational regime. However, there are a small number of low active, high risk effluents which must continue to be managed for many years. 184. In addition, as Sellafield Site moves from a regime of largely commercial reprocessing operations to largely POCO and decommissioning, effluents currently classified as ‘low risk’ may become ‘high risk’ owing to the change in operating mode to that of clean-up taking place. Diverting these streams towards EARP Bulks provides mitigation against this risk. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 45 of 61 185. The SETP deals with low activity, low risk feeds, and these will also reduce significantly after reprocessing operations cease. It was determined that EARP Bulks has the hydraulic capacity to accommodate its own residual feed and SETP residual feeds (see graph below), with the exception of the purge of the Light Water Reactor (LWR) fuel pond. The LWR pond purge has an existing alternative discharge route via SIXEP. Volume Into EARP Bulks 140000 Volume, m3/yr 120000 100000 80000 Combined SETP Other EARP Magnox Volumetric Capacity LTP2007 60000 40000 20000 20 07 /0 20 8 09 /1 20 0 11 /1 20 2 13 /1 20 4 15 /1 20 6 17 /1 20 8 19 /2 20 0 21 /2 20 2 23 /2 20 4 25 /2 20 6 27 /2 20 8 29 /3 20 0 31 /3 20 2 33 /3 20 4 35 /3 20 6 37 /3 20 8 39 /4 0 0 Figure 17 - Graph showing the impact as SETP feeds are diverted in EARP upon its hydraulic capacity 186. Diverting the low risk, low active effluents from SETP into EARP enables SETP to cease normal operations earlier than its currently identified date. Whether SETP undergoes POCO and subsequent early remediation, or a period of extended care and maintenance subject to SIXEP contingency or decommissioning options, is to be established. 187. Therefore the proposed baseline strategy that has been included in 2008 LTP is that when the volume of residual effluent arisings to SETP and EARP has fallen below the EARP hydraulic capacity, Low Active Low Risk effluents will be diverted towards EARP Bulks. This extends the operation of EARP, Effluent Plant Maintenance Facility (EPMF) and WPEP from 2030 to 2040, thus enabling SETP closure to be brought forward from 2040 to the end of Magnox and Thorp POCO phase (predicted to be circa 2017). 188. A detailed technical assessment, supported by comprehensive report, has been carried out based on the OES model for future SETP effluent arisings and the impact of diverting these streams to EARP. In summary the technical judgement does not identify any significant show stoppers for diversion and identifies the following key points requiring further assessment: 189. EARP Bulks is unlikely to remain viable after the cessation of reprocessing due to the small volume of residual feeds. • EARP Bulks has the hydraulic capacity to receive and process all residual SETP feeds after cessation of reprocessing, with the exception of the LWR Pond purge. • The LWR Pond purge already has an engineered discharge route via SIXEP. • Of the residual SETP feeds, all were broadly compatible with EARP Bulks apart from the HALES Caustic Scrubber (due to volatile active species); it may be still possible to divert the HALES Caustic Scrubber effluent into EARP Bulks without detriment to aerial releases. • The processing of complexants, although already carried out in very small and diluted batches, requires better definition regards future arisings. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 46 of 61 • There is a cost penalty arising from increased generation of floc from EARP, which results in an increase in ILW product drums: OES modelling indicates around 4000 extra product drums, but this could be significantly reduced to around 400 if EARP can be demonstrated to operate effectively at lower iron concentration in the feed. 190. It is noted that cost benefit is difficult to quantify at this stage of the strategy development. The issue is complicated by issues of potentially maintaining SETP operational readiness to provide contingency against irrecoverable outage of SIXEP and possible Decommissioning opportunities. Cost impacts dependent on strategic use need to be built up during detailed design of the most effective engineered diversion option for SETP feeds. A cost neutral output would support the option for early diversion. 191. It is envisaged that the combined residual low risk effluent volume will fall within the capacity of EARP bulks around the completion of both Magnox and Thorp reprocessing and POCO phases (predicted to be circa 2017). 192. Development work is required from now to confirm EARP and WPEP operability, and to identify modifications required to the Low Active (LA) drainage system (including segregation of the HALES Caustic Scrubber effluent). 193. Key Recommendations: • Assess modifications required to divert SETP feeds into EARP Bulks • Develop a methodology for carrying out limited development work on actual SETP feeds through EARP using existing engineered route 4.2.4 Future Low Active Aqueous Effluent Strategy 194. The OES for Sellafield that was delivered as part of the Sellafield “Gate C” Strategy in March 2006 did not develop the aqueous effluent strategy beyond 2040 due to the lack of definition of effluent arisings in this period. 195. 2007 LTP assumed the main existing liquid effluent plants would be closed by around 2040 due to age and redundancy. EARP closes around 2030; SETP and SIXEP close around 2040. No replacement plants are proposed. Current infrastructure for low active effluent, surface and groundwater collection and discharge remain until around 2090 to handle residual effluents. Since the OES was not developed during this timeframe there are a number of disconnects which need addressing: • Current assets were designed for the site as it operates now and are unlikely to be fit for purpose during the radically different site activities taking place from 2040 onwards. • In order to complete remediation of Separation Area it is necessary to remove the current effluent collection, treatment and discharge assets. 196. By 2040, process LA effluent arisings are predicted to have virtually ceased. Residual LA effluent producers are confined to a small number of plants and support facilities. LA effluent arisings in this time period are expected to broadly comprise: 3 • Process effluents, mainly from fuel ponds and stores operations (around 25,000 m /year) 3 • Decommissioning effluents (100’s m /year total from all sources) 3 • Contaminated surface and ground water (around 500,000 m /year) The major volumetric component of liquid effluent will therefore arise from the management of groundwater and surface water drainage. As Separation Area is progressively remediated the potential activity and volume of contaminated water will fall. 197. Proposed baseline strategy for 2008 LTP: • New East River Effluent Collection System (ERECS) and West River Effluent Collection System (WRECS) will be provided for LA effluents arising east and west of the River Calder respectively, from 2040 onwards. This will provide Sellafield with two separated LA effluent systems. • Residual active effluents arising east of the River Calder are treated at source to be suitable or sea discharge. They undergo accountancy at source, and are collected and discharged via the ERECS and the existing Calder Interceptor Sewer, possibly via a coaxial pipe laid through the sewer. • Residual active effluents arising west of the River Calder are treated at source to be suitable for sea discharge. They undergo accountancy at source, and are collected and discharged via the WRECS and a new or refurbished sea line. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 47 of 61 • Minor effluent arisings from decommissioning activities will undergo treatment and accountancy at source. They will then be transferred by bowser to the WRECS. Figure 18 – Map showing each of the new effluent collection systems and their discharge routes. The diagram also shows the expected status of buildings at 2040 according to 2007 LTP. 198. An alternative strategy under consideration is for effluents generated at East Calder to be pumped across a pipebridge to the WRECS. This would result in a single sea discharge point for all active effluents. 199. No site allocation has been made for these facilities yet. WRECS would be expected to be south or south west of Separation Area, near to the existing sea line route; ERECS would be expected to be in the region of the Waste Inlet Facility (WIF) and Comprehensive Import Export Facility (CIEF), the main sources of low active effluent arising. 200. It is envisaged that the new effluent collection and discharge systems would be operational around 2040. Development and design of the new systems would be carried out in the 2030s, by which time firmer assessments of the expected demand, regulatory regimes and stakeholder expectations would be available. 201. Major refurbishment or replacement around 2070, coincident with expected completion of Separation Area remediation, would enable new demand predictions to be accommodated. 202. The changes to the Sellafield low activity effluent strategy has been assessed using the same methodology as performed in IWS Version 2. As a result, Figure 19 shows the Sankey diagrams that are relevant to this strategic change. The top one of the two diagrams shows the situation as reported in LTP 2007, whereas the diagram beneath is indicative of the revised strategy. It is worth noting that there are two additional streams on the revised Sankey, these are examples of new opportunities that have been identified since the production of 2007 LTP. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 48 of 61 LTP2007 Wet Inlet Facility Local Effluent Treatment Plant 2505 m3 Misc. Beta Gamma Waste Store Sellafield Product & Residue Store Borehole 68 18 m3 Sellafield Effluent Treatment Plant 120 m3 4745 m3 Break Pressure Tank Thorp Receipt & Storage Local Effluent Treatment Plant 18800 m3 Lagoon Surface Water 342005 m3 LTP2008 - Opportunity for East & West River Effluent Collection Systems Wet Inlet Facility Local Effluent Treatment Plant Surface Water Comprehensive Import & Export Facility Separation Area Groundwater Effluent Treatment Facility Borehole 68 4745 m3 Thorp Receipt & Storage Local Effluent Treatment Plant 18800 m3 2505 m3 56 m3 Sellafield Product & Residue Store 120 m3 Miscellaneous Beta Gamma Waste Store 18 m3 342005 m3 198195 m3 West River Effluent Collection System East River Effluent Collection System Figure 19 – Sankey diagrams showing the change in strategy since 2007 LTP for the low activity effluent collection system © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 49 of 61 4.2.5 203. Discharge Trends The graphs below demonstrate the current predicted discharge trends and also illustrate the current targets of the UK Discharge Strategy. LTP 2008 Predicted Dose Attribution from Liquid Effluents allocated to Reprocessing & Decommissioning 30 25 Sv 20 15 10 5 0 2005 2007 2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 Financial Year Starting Predicted Reprocessing Contribution Predicted Decommissioning Contribution UK Discharge Strategy Target Figure 20 - Predicted trend for dose attributed to liquid effluents, showing the discharge from reprocessing and decommissioning operations. LTP 2008 Predicted Total Alpha Attribution from Liquid Effluents allocated to Reprocessing & Decommissioning 0.4 0.35 0.3 TBq 0.25 0.2 0.15 0.1 0.05 0 2005 2007 2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 Financial Year Starting Predicted Reprocessing Contribution UK Discharge Strategy Target Predicted Decommissioning Contribution Figure 21 – Predicted trend for total alpha discharges from reprocessing and decommissioning operations LTP 2008 Predicted Beta-5 Attribution from Liquid Effluents allocated to Reprocessing & Decommissioning 90 80 70 TBq 60 50 40 30 20 10 0 2005 2007 2009 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 Financial Year Starting Predicted Reprocessing Contribution Predicted Decommissioning Contribution UK Discharge Strategy Target Figure 22 - Predicted trend for beta-5 discharges from reprocessing and decommissioning operations © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 50 of 61 204. As can be seen from the graphs above, the discharges due to reprocessing are currently low owing to the low throughput of the reprocessing plants in recent years. The slight increase in discharges over the next few years will be due to the planned ramp-up of reprocessing operations to operate closer to previous rates. Once reprocessing operations cease, the associated discharges will reduce considerably and quickly, though discharges due to retrievals of legacy wastes and decommissioning operations become more significant. It can be seen that the projected discharges meet the UK Discharge Strategy target, though it should be understood that projected discharges due to decommissioning operations inherently carry a greater degree of uncertainty than those for reprocessing operations. It should also be noted that the UK Discharge Strategy target does not preclude additional reprocessing business, should the UK Government choose to progress that opportunity. 4.3 Gaseous Waste Strategy 4.3.1 Update of the Gaseous Waste Strategy 205. The overall effluent strategy work is also relevant to the IWS. Decisions by the IWSSG are taken with due regard to the OES work regarding both aqueous and gaseous wastes. The OES is used to inform the overall Integrated Strategy for Sellafield. With reference to gaseous wastes, the strategy is focused upon supporting and enabling commercial operations and remediation activities at Sellafield, whilst ensuring adequate protection of the environment. 206. Current operations at Sellafield result in several main gaseous effluent streams that have the potential to contribute to radioactive discharges to the atmosphere. These include: • Reprocessing Operations • HLW Treatment • Spent Solvent Treatment • Legacy Waste Storage 207. Reprocessing operations contribute the most towards gaseous discharges. Therefore, once reprocessing finishes, a significant reduction in amount of gaseous activity released is expected to be seen. Since June 2007 the main contributor to gaseous discharges has been legacy ponds as both HLW Treatment and Reprocessing Operations have been curtailed owing to a lack of Evaporative capacity for treating HAL waste. 208. All significant gaseous waste streams are subject to treatment prior to discharge. The use of these facilities represents the BPM for minimising discharges, and the application of the WMH. When treating gaseous streams, emphasis is placed on abatement. The aim of which is to contain the radioactivity in solid or aqueous form, thus immobilising or mitigating the environmental impact of the activity. 209. The current Gaseous Waste Strategy remains the same as for the 2007 IWS (Version 2) i.e. the existing Gaseous Waste Baseline Statement remains the current state of the strategy. 210. Aspects of the strategy that may be subject to change are: • The impact of the funding shortfall upon the Separation Area Ventilation (SAV) project, • Subjective reports of larger than anticipated deflections of the Alpha Plant Discharge Stack during winter storms. These are discussed in the sections below. 4.3.2 211. Separation Area Ventilation Project Both the first generation reprocessing plant stack (that serves Magnox reprocessing plants, various legacy and storage plants, and some plants that are being decommissioned) and the Pile 1 stack are nearing the end of their effective operational lives and are scheduled for demolition in the near future. The objective of the SAV Project is to divert aerial effluents currently routed to these stacks to a new discharge facility that will provide a long-term discharge capability to meet current and future operational and decommissioning needs. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 51 of 61 212. The SAV project is a critical part of the current gaseous waste strategy. It has recently been subject to a financial review following the current lack of NDA funding to deliver baseline projects. The review has further strengthened the case for the SAV project, though it has caused the project delivery to slip by approximately three months. 4.3.3 213. The stack that jointly serves the Analytical Services Facility and the Product Finishing & Storage Facility provides a suitable high discharge point for the ventilation systems of these plants. Routine design checks carried out as part of the Continued Operation Safety Report (COSR) preparation and visual inspections of accessible parts of the stack give confidence in the integrity of the structure. Further assurance to allay concerns of previous subjective reports of larger than anticipated deflections during winter storms is being performed in the form of instrumentation to assess any movement of the stack over several months; this is done because of firstly the previous lack of measurement of the deflections and secondly to build on the confidence of the COSR design checks. All indications to date confirm the stack to be adequate for the requirements upon it (i.e. at least 5 years). Therefore it is noted that there should be sufficient time to provide a solution should the monitoring instrumentation indicate any problems with the longer term use of the stack. 4.3.4 214. Alpha Plant Discharge Stack Discharge Trends The graphs below were produced by the OES Model (OESM) for 2008 LTP, using the best available data at that time. The graphs refer to predicted aerial discharges from the main (scheduled) stacks on the Sellafield site, and do not include discharges from Miscellaneous Outlets on the site. It should be noted that the OESM currently over-predicts aerial discharges and hence the associated dose to the critical group by a significant margin (an approximate factor of 2.5), for example, in the graph below the dose to the critical group is predicted to be around 50µSv, but actual discharges were measured closer to 20µSv. Further improvements to the aerial modelling capability are planned within the OES work, but it may be several years before modelled predictions become close to actual discharges. LTP 2008 Predicted Dose Attribution from Aerial Effluents allocated to Reprocessing & Decommissioning 60 50 Sv 40 30 20 10 0 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Financial Year Starting Predicted Reprocessing Contribution Predicted Decommissioning Contribution Figure 23 – Predicted trend for dose attributed to aerial effluents, showing the discharge from reprocessing and decommissioning operations © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 52 of 61 LTP 2008 Predicted Total Alpha Attribution from Aerial Effluents allocated to Reprocessing & Decommissioning 3.00E-04 2.50E-04 TBq 2.00E-04 1.50E-04 1.00E-04 5.00E-05 0.00E+00 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Financial Year Starting Predicted Reprocessing Contribution Predicted Decommissioning Contribution Figure 24 – Predicted trend for total aerial alpha discharges from reprocessing and decommissioning activities LTP 2008 Predicted Beta-5 Attribution from Aerial Effluents allocated to Reprocessing & Decommissioning 7.00E-02 6.00E-02 5.00E-02 TBq 4.00E-02 3.00E-02 2.00E-02 1.00E-02 0.00E+00 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 Financial Year Starting Predicted Reprocessing Contribution Predicted Decommissioning Contribution Figure 25 – Predicted trend for beta-5 discharges from reprocessing and decommissioning activities 4.4 Decommissioning 4.4.1 Decommissioning Strategy (including mandates) 215. The most significant change to the Decommissioning Strategy since Version 2 of the Sellafield IWS was issued (June 2007) has been the inclusion of uncertainties in the assessment of the volumes of waste that will be generated during decommissioning of Sellafield. This has significantly increased the projected volumes of waste and hence has directly affected the strategies for treating and disposing of this waste. The impacts on the affected strategies (e.g. LLW, PCM, ILW, etc) have been discussed in earlier sections of this report. The full impact of the uncertainties upon the Decommissioning Strategy is unlikely to be known until 2009 LTP is prepared, as it is inevitably linked to funding, and 2009 LTP will be prepared from a strategic viewpoint that assumes it is fully-funded. 216. The programme of revised decommissioning estimate production, formally called the Decommissioning Mandate process (which are assessments of how to decommission specific plants, together with projected costs and waste volumes) were subject to scope review in May 2008 to ensure the most benefit is gained from the work. Decommissioning Mandates have been carried out on 22 plants to date, including the major facilities on site. This review assessed the output of the mandates performed to date and will direct the future programme of work on mandates. This will involve consideration of a range of approaches to decommissioning, including techniques, costs, programmes, etc. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 53 of 61 217. Those estimates completed so far have given confidence in the revised figures for cost, schedule, waste volume, etc, together with a slight change in strategic direction towards targeted waste segregation at the decommissioning workface. The new estimates have also enabled an improved understanding of the state of the plant following POCO and hence a better idea of the decommissioning start-point – which gives a better idea of where targeted decontamination may be useful. This is a change from the previous general approach of remote dismantling and minimal decontamination in more highly-active areas. 4.5 Non-Radioactive Discharges 218. The Sellafield site received a Pollution, Prevention and Control (PPC) permit in October 2007. Table S1.3 in Schedule 1 of the PPC permit specifies activities required by the EA as part of the permit process. 219. One of these improvements is the review of fugitive aerial emissions. Initial work has identified the key aerial non-radioactive species of interest (such as dust, heavy metals, oxides of NOx and SOx) and is now seeking to use the existing aerial environmental measurements at the site perimeter (using the High Volume Air Samplers) to prove that emissions of these species from the site are, as anticipated, insignificant. Should these results be otherwise then further work will be undertaken to improve understanding. 220. In the past year the main source of the steam supply to the site, the 3 Combined Heat & Power (CHP) plant gas turbines, suffered a common mode failure of corrosion of all 3 exhaust stacks. For safety reasons the heights of the stacks were reduced. As a result, a review was needed to assess the impact of operating at a lower stack height, and whether the CHP plant could continue to operate in its modified state. Sellafield Ltd have assessed the affect of reduced stack heights and shown that the increase in ground level concentrations of nitrogen dioxide to members of the public and key environmental receptors are small and will have a negligible impact on both human health and the wider environment. 221. It was concluded that reduced stack heights does not result in a breach of the permitted emission limits, however it does represent a change to the agreed operating technique. The variation was submitted to the EA who agreed in February 2008 that discharges from CHP would be acceptable and would not exceed the limits set on the site for NOx. Therefore the CHP plant can continue to operate, and hence maintain a reliable source of steam to the site. 222. A number of facilities on site require and depend on a reliable source of steam. The recent event whereby the stacks on the CHP steam generating plant were found to be corroded, and therefore their heights reduced, had the potential to threaten the supply of steam to the site. The decision was taken to maintain steam production so that site operations could continue. This demonstrates the principles of the IWS and improved application of the WMH. When assessed, it was considered that the production of steam was critical to the primary focus of safety and risk reduction. In addition, the issue surrounding the CHP plant provides an example of the integrated nature of the site, and the inter-dependency of plants. 223. As part of the PPC permit, Sellafield Ltd is also obliged to: Take appropriate measures to ensure energy, raw materials & water are used efficiently in the activities on the site, and to apply the waste management hierarchy appropriately to avoid & minimise waste generation. Review every 4 years whether there are suitable opportunities to improve the efficiency of the activities, and take appropriate measures based upon these reviews. 224. Continuing to integrate and optimise the Sellafield IWS to fully include non-radioactive wastes is an ongoing development target for the site. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 54 of 61 5.0 Opportunities, Risks & Uncertainties 225. At both site level and at the component strategy level there are uncertainties, risks, and opportunities that impact on, or are relevant to, the IWS. 226. Uncertainties The previous version of the IWS (2007) identified the following uncertainties for which Sellafield is dependant upon national policy/decisions and their resolution: • Repository design, timing and location • Decision on the future of LLWR • UK Policy on plutonium and uranium • The potential for future use of Sellafield as a national asset for waste management Since then, two significant additional uncertainties have arisen having the potential to impact on the IWS. Both the current funding situation and the imminent DEFRA review of the UK Strategy for Radioactive Discharge 2006-2030 are outside the control of the IWS. When these uncertainties are resolved the implications will be assessed to inform the IWS. 227. Risks There are a number of risks that have the potential to impact upon the Sellafield IWS. These are summarised at a high level in Table 6 which details the actions being taken to manage these risks. Table 6 – Potential future risks that may impact upon the Sellafield IWS Risk Action to mitigate LLW A change in the Condition for Acceptance (CFA) of a future LLWR may require more stringent processing that currently employed (e.g. a greater degree of radiometric segregation, passivation of wastes, etc.) Constraints on disposal to the current LLWR or the unavailability of a future LLWR may lead to on-site storage To be assessed within the developing Sellafield & national LLW strategy (June 2009) Inappropriate use of waste routes, e.g. large quantities of HVVLLW being disposed of to LLWR if not effectively segregated at source LLWR costs increasing as capacity becomes more constrained Uncertainty in decommissioning forecasts may increase LLW disposal costs As above, and assessed within the developing decommissioning strategy ILW / PCM Change in Repository Waste Acceptance Criteria – may lead to greater level of pre-conditioning and/or potential for higher level of rework on existing packages. Increased scope for the extent of re-work required than that currently envisaged (e.g. may have to chemically treat waste instead of simply over-packing) Delay in repository availability – wastes would require prolonged storage, forcing stores to operate beyond current design lives. Currently being assessed within OU – Final Treatment and disposal of ILW, and the PCM Strategy. Uncertainty on decommissioning and legacy waste forecasts and characterisation - may increase rework and final disposal costs. As above, and assessed decommissioning strategy within the Site Wide Internal High activity evaporators capacity limits reprocessing throughput and the clean up of HLW plants Problems in the LP & LS schedule Managed within current 2007 LTP and HLW strategy As above, and addressed in the LP & LS strategy Fuel reprocessing is extended Managed within 2007 LTP and strategies for Magnox Operating Plan and Oxide Operation Plant Managed within the 2007 LTP and the developing LLW strategy LLWR reaches capacity Note: Effluent Risks are not included in this table as the actions to mitigate these have already been developed to a sufficient extent to be incorporated into the relevant parts of the Sellafield LTP (e.g. SIXEP Contingency and SETP-EARP switch). © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 55 of 61 228. There remain lower-level risks, specific to the component strategies, which if realised could affect the tactics of the component strategies. Under such circumstances the ‘flankguard’ role of the IWS is to ensure that a change in tactics does not affect the intended strategic direction. 229. Opportunities There are several opportunities identified in the relevant OU LTPs that are relevant to the IWS. These are briefly outlined as follows: 230. Opportunities for LLW • Potential for treatment plants to become available earlier than scheduled in 2008 LTP if a Private Finance Initiative (PFI) arrangement is used. • Significant increase in decontamination if chemical techniques are employed. • Significant opportunity to recycle and reuse any HVVLLW on-site if demonstrated to be within acceptable radiological limits. • Cracking and crushing LLW concrete may allow for better packing efficiency and recovery of re-bar • Investment in cable stripping would offer significant recovery and sale of valuable materials such as copper and aluminium. 231. Opportunities for ILW Utilisation of existing and planned ILW treatment facilities (e.g. MEP, WEP, BEP, etc) which may obviate the need for the 1st ILW conditioning plant - Decommissioning Intermediate Level Waste Encapsulation Plant (DILWEP) – identified in the Final Treatment and Disposal of ILW OU as being currently required. There may be an opportunity to instead use existing spare capacity and future LP&LS treatment plant spare capacity to treat decommissioning waste. This requires significant scheduling work and there is a potential delay to decommissioning. Risk management will be a significant burden. 3 Potential to use larger packages (than 3m boxes) for decommissioning wastes – this will allow for more efficient packing. Decontamination and volume reduction of bulk metals to reduce disposal volumes, costs and apply the waste hierarchy more effectively. Increased rate of ILW exports to the repository thereby reducing the overall duration of site storage and export – cost savings and reduced likelihood of store replacements. Consolidate final ILW treatment facility with that required for Calder Hall Final Site Clearance. Decay store significant quantities of lower order decommissioning ILW and remove requirement for disposal. Improved characterisation of waste may enable re-categorisation of some waste to a less onerous waste category Potential avoidance of some additional stores through reducing the uncertainty around future waste volumes 232. All of these opportunities are subject to further assessment of technical underpinning and potential secondary consequences in order to determine whether it is appropriate to incorporate these changes into the strategic baseline. As appropriate, these opportunities will then be pursued by the relevant OUs and component strategies through the LTP process and implementation is being assured via the Strategic Governance arrangements in place on the site. 6.0 Conclusions & Way Forward 233. The NDA state that an IWS is a strategy which describes; • How a site optimises its approach to waste management in an integrated way. • The waste streams and discharges expected from current and future operations. • Actions that are required to improve the sites approach to waste management. 234. In its current form the IWS for Sellafield describes: 235. How the site approached waste management in an integrated way – The largely ‘integrated’ position established by Version 2 (June 2007) has been successfully strengthened in the past 12 months through the tactical deployment of the IWS principles developed in IWS V2 (2007) within the component waste strategies and OU work plans. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 56 of 61 236. The waste streams and discharges expected from current and future operations – these predictions are covered in section 4. 237. Actions required to improve the sites approach to waste management This update describes how the actions to improve the sites approach to waste management have been embedded into the LTP for the site and notes those opportunities for further improvement which are still being pursued. 238. Over the past three years the Sellafield IWS has developed from being a statement of the baseline strategy (Version 1, June 2006) to a mature and live strategy process fully embedded in the site LTP. Since Version 2 considerable progress has been made in translating this strategy into the LTPs for the site. In particular: • all wastes and routes have been identified • estimates quantities of waste have been reassessed for both raw and conditioned volumes • Opportunities have been identified for waste minimisation and the use of existing facilities. These have either been incorporated into the lifetime or identified for further assessment. • Strategies for implementation are being developed for LLW, ILW and PCM • Tools and techniques to facilitate quantification and assessment and to enable the visible management of wastes information have been developed e.g. Sankey Diagrams in Version 2 and the OESM. • The analysis has contributed to the NDA led national strategies in particular ILW and LLW strategies. 239. The IWS in its present form fulfils all of the above requirements with the exception of optimisation. 240. It is difficult to fully optimise the IWS whilst high-level uncertainties remain around funding, waste volumes, scheduling and waste characterisation. The next ‘step-change’ in IWS development will be achievable once these uncertainties are sufficiently resolved and optimisation around a set of ‘fixed’ parameters can be undertaken. In the meantime the Sellafield IWS will continue to integrate and optimise the site’s component waste strategies within these constraints and will inform and support the development of national strategies which will help resolve these uncertainties. 241. Way Forward The way forward for the component strategies is best summarised in Figure 26, which illustrates the key timelines for these strategies and how these are influenced by site operations, external influences and other constraints. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 57 of 61 Figure 26 – Future milestones associated with the IWS © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 58 of 61 242. In the immediate future (2008-09), there is a requirement to produce a combined IWS with the Windscale licensed site by June 2009. The next iteration of the IWS will also be informed by the emerging Sellafield and national LLW Strategies. 243. This update of the IWS has reported and discussed the tactics and deployment of the Sellafield IWS. The component strategies will continue to implement the principles of the IWS and hence the future development of the IWS will be as a ‘flankguard’ role to: • ensure the general strategic direction is maintained, regardless of changes to tactics that may be needed in the future • undertake assessment of potential strategic changes initiated by resolution of uncertainties or changes in assumptions 244. It is recognised that there is still some implementation work to be done and some opportunities to be pursued within the LTPs. This work will be undertaken by the relevant OUs with the IWS team (within Strategy and Transition group) providing a ‘flankguard’ role going forward and using appropriate Strategic Governance arrangements to ensure delivery. © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 Page 59 of 61 7.0 Glossary Abbreviations Full Text AGR AWE AGWSG AWS Advanced Gas-Cooled Reactor Atomic Weapons Establishment (at Aldermaston) Aqueous Gaseous Waste Strategy Group Aqueous Waste Strategy Becquerel (Bq) BEP BFS BNFL BPEO BPM BS C-14 CEAR CFA CHP Ci CIEF CILWS CLESA cm COSR Cs-137 DEFRA DILWEP DoE DQO EA EARP EDS EN EPMF EPS ERECS FY g HA HAL HALES HAST HHISO HLW HLWP HVLA HVVLLW ILW ISO The SI unit of radioactivity. A becquerel is the smallest unit of radiation – it corresponds to the activity of a quantity of radioactive material in which one nucleus decays per second Box Encapsulation Plant Blast Furnace Slag British Nuclear Fuels Limited Best Practicable Environmental Option Best Practicable Means British Standards Carbon-14 Compilation of Environment Agency Requirements Conditions For Acceptance Combined Heat & Power Curie, unit of radioactivity Comprehensive Import Export Facility Containerised Intermediate Level Waste Store Calder Landfill Extension Segregated Area Centimetres equal to 10^-3 Metres Continued Operations Safety Report Ceasuium-137 Department for Environment, Food and Rural Affairs Decommissioning Intermediate Level Waste Encapsulation Plant Department of Environment Data Quality Objectives Environment Agency Enhanced Actinide Removal Plant Engineered Drum Store Enforcement Notice Effluent Plant Maintenance Facility Encapsulated Product Store East River Effluent Collection System Financial Year Gram, SI Unit for Mass Highly Active Highly Active Liquor Highly Active Liquor Evaporation and Storage Highly Active Storage Tanks Half Height International Standards Organisation High Level Waste High Level Waste Plant High Volume Low Activity High Volume Very Low Level Waste Intermediate Level Waste International Standards Organisation © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 60 of 61 Abbreviations Isotope IWS IWS V2 IWSSG km KPI LA LFE LLLW LLW LLWR LP&LS LSG LSTP LTP LWR m MAC MASFE MASWEP MBGWS MEB MEP MOP ND&MPG NDA NII NNL NOx OES OESM OPC OSPAR OU PAF PBI PBO PCM PCRSA PFA PFI PFSTP PMP POCO PPC PPE PVC R&D REF RSA 93 Full Text A subtype of an element – isotopes of an element have the same number of protons, but different numbers of neutrons. The most common in nature are stable isotopes, radioactive isotopes are unstable – radiation is a by-product of an isotope moving towards a stable form. Integrated Waste Strategy Integrated Waste Strategy Version 2 Integrated Waste Strategy Steering Group Kilometre, equal to 1000 metres Key Performance Indicator Low Active Learning From Experience Low Level Liquid Waste Low Level Waste Low Level Waste Repository Legacy Ponds & Legacy Silos (National) Low Level Waste Strategy Group Local Sludge Treatment Plant Lifetime Plan Light Water Reactor Metre, SI Unit for Distance Medium Active Concentrate Medium Active Salt Free Evaporator Medium Active Solid Waste Encapsulation Plant Miscellaneous Beta Gamma Waste Store Multi Element Bottle Magnox Encapsulation Plant Magnox Operating Plan Nuclear Decommissioning & Major Projects Group Nuclear Decommissioning Authority Nuclear Installations Inspectorate National Nuclear Laboratory Nitrogen Oxides Overall Effluent Strategy Overall Effluent Strategy Model Ordinary Portland Cement Oslo-Paris European Union Convention Operating Unit Performance Agreement Form Performance Based Incentive Parent Body Organisation Plutonium Contaminated Material Post Closure Report Safety Assessment Pulverised Fuel Ash Private Finance Initiative Pile Fuel Cladding Silo Treatment Plant Plant Modification Proposal Post Operational Clean Out Pollution, Prevention & Control Personal Protective Equipment Poly Vinyl Chloride Research & Development Residue Export Facility Radioactive Substances Act 1993 © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008 Page 61 of 61 Abbreviations Full Text RWMAC SAV SDP Radioactive Waste Management Advisory Committee Separation Area Ventilation Silos Direct Encapsulation Plant Sellafield Ltd The new name for British Nuclear Group, Sellafield Ltd operates the Sellafield site on behalf of the NDA Segregated Effluent Treatment Plant Site Funding Limit The SI unit of dose equivalent. A Sievert is a measure of biological dose – which is the biological impact of radiation. A Sievert is a large impact and hence most discharge impacts are measured in small fractions of this i.e. thousandths (mSv) or millionths (µSv). Site Ion Exchange Plant Site Ion Exchange Plant Operating Plan Site Ion Exchange Plant Operating Strategy Site License Company Sulphur Oxides Sludge Packing Plant Strontium-90 Sellafield Site Procedure SIXEP Waste Processing Plant Site Ion Exchange Plant Waste Retrievals Technical Baseline: Underpinning Research & Development Technicium-99 Tonne (equal to 1000kg) Thermal Oxide Reprocessing Plant United Kingdom United Kingdom Atomic Energy Agency United Kingdom Nuclear Waste Management Limited Very Low Level Waste Vitrified Product Store Vitrified Residue Waste Materials and Compaction West Cumbria Site Stakeholder Group Waste Encapsulation Plant Waste Inlet Facility Waste Management Hierarchy Waste Packing and Encapsulation Plant West River Effluent Collection System Waste Treatment Complex Waste Vitrification Plant Alpha, in reference to alpha radiation Beta, In reference to beta radiation SETP SFL Sievert SIXEP SixOP SixOS SLC SOx SPP Sr-90 SSP SWP SWR TBURD Tc-99 te THORP UK UKAEA UKNWM VLLW VPS VR WAMAC WCSSG WEP WIF WMH WPEP WRECS WTC WVP © Nuclear Decommissioning Authority 2008, this document contains proprietary information, permission to copy, or use such information, should be sought from the Intellectual Property Manager, Sellafield Ltd. Sellafield Integrated Waste Strategy – Update on Version 2 June 2008
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