RSRL Integrated Waste Strategy - Issue 5- Oct 2012.pdf

NOT PROTECTIVELY MARKEDRSRL Waste Policy &Reference:NDA/038/IWSIssue: Issue 5ComplianceDate: October 2012RESEARCH SITES RESTORATION LTDINTEGRATED WASTE STRATEGYName and Organisation Signature DateRevisedBy:Sam CoxWaste Strategy ManagerRSRLCheckedBy:Alan FisherWaste Policy & Compliance ManagerRSRLApprovedBy:Tony WrattenManaging DirectorRSRLRSRL IWS (Issue 5 – October 2012)1

NOT PROTECTIVELY MARKEDhistoric arisings in tube stores at Harwell. The processing of SGHWR sludges atWinfrith into a passively safe form was completed in March 2010.• Recognition that future arisings range from ILW and LLW through to hazardous andnon-hazardous exempt (“out of scope”) waste which will be produced during thedecommissioning of the reactors, waste management facilities and buildingscontaining low or no activity. This includes high volume very low level waste (HV-VLLW) and Low Activity Low Level Waste (LA-LLW) suitable for disposal at landfill 2 .• The assumption that ILW arising from decommissioning activities at both Winfrithand Harwell will be stored on the Harwell site until a Geological Disposal Facility(GDF) is available for disposal. This is in line with current NDA Strategy (effectiveApril 2011) and the findings of the UK HAW Storage Review which encourages theoptimisation of waste management solutions by using assets across the NDA estate.ooAt Winfrith the solid ILW from the SGHWR and Dragon reactors will bepackaged and grouted into Robust Concrete Boxes (RCBs) along with ILWconcrete lined drums and stored uranium. These will be transferred to theHarwell ILW store for interim storage pending disposal to the GDF. Thoriummetal at Winfrith will be transferred to Harwell in 200 litre drums for interimstorage. Whilst the baseline strategy for the thorium is to package and groutit into RCBs prior to disposal to the GDF, RSRL is actively pursuing sale forre-use in the fuel cycle.At Harwell, ILW will be packaged into a mixture of 500 litre drums, RCBs and3m 3 boxes. The Vault Store will continue to store the legacy wastes in 500litre drums and a new on-site ILW store will be built to take the RCBs and3m 3 boxes containing RSRL decommissioning waste until the GDF isavailable.• The transfer of wastes containing nuclear materials to Sellafield for onwardprocessing and long-term storage pending final disposal to a future GDF. Thesewastes are currently stored on the Harwell site.• Whilst the strategy is to consign LLW arising during the site programmes at Winfrithand Harwell to the LLW Repository (LLWR) near Drigg alternative disposal routes inline with the RSRL and LLWR Joint Waste Management Plan are being developedand will be reflected in future updates of the IWS.• The disposal of cemented SGHWR sludges, currently stored in 500 litre drums in theWinfrith Treated Radwaste Store (TRS), to the Low Level Waste Repository (LLWR).• The disposal of high volume very low level waste (HV-VLLW) and Low Activity LowLevel Waste (LA-LLW) to suitable landfill facilities. With a large volume of LA-LLWand HV-VLLW arising from decommissioning and land remediation alternatives todisposal at LLWR have been considered and a route established in early 2012. Thisroute is being successfully utilised by the Harwell site and its continued availability isa key issue for the organisation. Having established at a BAT AssessmentWorkshop held in July 2012 that disposal to an appropriately Permitted off-sitelandfill is the preferred option for similar Winfrith wastes, arrangements are beingmade to develop this route for the Winfrith site also.2Formerly known as HVLA wasteRSRL IWS (Issue 5 – October 2012)3

NOT PROTECTIVELY MARKED8. There have been some minor changes in the timing of the current Harwell programme sincethe LTP Baseline March 2012. The Harwell site final end state has been reduced by 1 yearfrom 2051 to 2050 as a result of ex-GE Healthcare CLDs being disposed of as part of theNuclear Materials Transfer project rather than directly to the GDF from Harwell. Whilst therehas also been a change in strategy to transfer Winfrith ILW to Harwell for storage andeventual disposal to the GDF this does not extend the Harwell programme as the sameshipping profile has been assumed as if the waste had been sent directly from Winfrith tothe GDF. RSRL is in regular communication with RWMD regarding the shipping profile forRSRL waste.9. The major change in the timing to the current Winfrith programme since the LTP BaselineMarch 2012 is the shortening of the site interim end state by 14 years from 2038 to 2024.This is as a result of implementing the outcome of the Winfrith Optimised Plan for earlyclosure of the Winfrith site. During 2012 the NDA asked Babcock to provide reach-backsupport through RSRL to develop an underpinned programme level business case for earlyclosure of the Winfrith site. The programme of work included development of technical andwaste management methodologies; underpinning schedule and cost data; and associatedstakeholder and implementation management plans. The changes include the earlycompletion of reactor decommissioning, the transfer of Winfrith ILW to Harwell for long-termstorage and the transfer of SGHWR sludges to LLWR rather than the GDF. The transfer ofILW to Harwell will negate the need to commission a new ILW store at Winfrith. The impactof the optimised programme on the Winfrith programme timescales is summarised in thetable below.MilestonePreviousCompletion DateNewCompletion DatePassive Safety of ILW achieved 2035 2022SGHWR Decommissioning complete 2038 2023DRAGON Decommissioning complete 2032 2021Minor Facilities Decommissioning complete 2038 2022Sea Pipeline Decommissioning complete 2040 2023Transfer of ILW off-site 2043 2022Winfrith Interim End State 2038 202410. The key decommissioning milestones identified in the current LTP baseline which impact onthe RSRL IWS include:Harwell• Passive safety of all ILW achieved by 2023• Material Test Reactors (MTRs) decommissioned by 2032• Solid Waste Complex fully decommissioned by 2049• Off-site disposal of ILW completed by 2047• All land delicensed and final end state achieved by 2050Winfrith• Passive safety of all ILW achieved by 2022• SGHWR and DRAGON reactors decommissioned by 2023• Off-site transfer of ILW completed by 2022• Interim end state by 2024RSRL IWS (Issue 5 – October 2012)4

NOT PROTECTIVELY MARKED11. Significant changes from Issue 4 of the RSRL IWS document include:• The change in strategy from the use of 2m boxes for Winfrith decommissioning ILW(all projects) and Harwell reactors decommissioning ILW to packing and grouting intoRobust Concrete Boxes• The transfer of Robust Concrete Boxes containing grouted Winfrith ILW to theproposed Harwell ILW Store for interim storage pending disposal to the GDF• The deletion of scope, schedule and costs for design, build and commissioning of anew ILW store at Winfrith• The transfer of Winfrith thorium metal to Harwell for interim storage pendingpackaging and disposal to the GDF. An opportunity to return it to the fuel cycle isbeing pursued• The transfer of encapsulated SGHWR sludges, currently stored in the TRS atWinfrith, to the Low Level Waste Repository rather than the GDF• The re-categorisation of some Harwell LETP Low Level legacy sludges from LLW toILW. These sludges have been encapsulated and will remain in interim storage inthe Solid Waste Complex pending final disposal to the GDF.12. The main challenges to the RSRL site strategy for waste are:• Obtaining planning permission to construct a new Harwell ILW Store fordecommissioning ILW from both Winfrith and Harwell sites in Robust ConcreteBoxes and 3m 3 boxes from 2017;• Ensuring that ILW packaged in RCBs meets the necessary transport requirementsand NDA RWMD standards.• Obtaining LLWR’s formal agreement to accept SGHWR sludges.• Successful implementation of the Nuclear Materials project involving the transfer ofDragon waste, CHILW in 200 litre drums, ILW in Concrete Lined Drums and LowEnriched Uranium (LEU) to Sellafield. There is still an opportunity to transfer LEU toSpringfields for processing through their Enriched Uranium Residues RecoveryPlant.13. Potential opportunities for improving waste management for consideration by NDA include:• Rationalise ILW Shipments to the GDF: Significant cost savings can be made if ILWis sent to the GDF faster than planned.• Early export of ILW from Harwell: Significant cost savings can be made if the GDFor interim off-site storage is available early as it would reduce the requirement forlong-term storage of ILW.• Sale of Thorium: There is the potential to return thorium to the fuel cycle for re-userather than disposing of it in the GDF. Thorium will not be processed until later inthe programme in order not to foreclose options.• Rationalise the use of RCBs: Using the same ILW boxes for all RSRL ILW wouldresult in a simplified design for the Harwell ILW store and hence reduce costs.• The processing of reactor graphite for disposal: The current strategy for reactorgraphite is to package it into Robust Concrete Boxes for storage then disposal in theGDF. The graphite at Harwell is small in volume when compared to the rest of thenuclear industry therefore there is an opportunity for NDA to consider a nationwidestrategy for graphite.• Alternative Treatment for Organic Liquid Waste: With the rising costs ofincineration, RSRL in conjunction with other NDA sites are currently looking atalternative options for treatment and disposal of organic liquid waste. AlternativeRSRL IWS (Issue 5 – October 2012)5

NOT PROTECTIVELY MARKEDmethods for the treatment and disposal of organic liquids could result in a more costeffective and BAT approach than incineration.14. External constraints and dependencies influencing the IWS include:• The availability of sufficient annual site funding particularly in relation to theoptimised plan for Winfrith.• The need to obtain planning permission for the construction of an ILW store atHarwell.• The need to obtain permission for Winfrith ILW to be transferred to Harwell for longtermstorage pending disposal to the GDF.• The successful implementation of the Nuclear Materials Transfer project andmeeting ONR requirements to downgrade the security level at Harwell.• LLWR’s agreement to accept SGHWR sludges, currently stored in the Winfrith TRS.• The continued availability of off-site disposal routes for Low Level Waste (includingvery low level waste and low activity low level waste) from operations,decommissioning and remediation.• Uncertainty in implementation and timing of the export of ILW to the GDF. This iscurrently assumed to be 2040.• The availability of a standard waste transport container (SWTC) to transfer packagedILW in drums from Harwell to the GDF.15. The key areas requiring further development to help improve the IWS include:• Progress planning permission for the Harwell ILW store.• Develop the use of RCBs for Winfrith ILW and ILW arising from Harwell reactordecommissioning.• Obtain LLWR’s agreement to accept SGHWR sludges.• Optimise the strategies for natural and depleted uranium.• Optimise the strategy for decommissioning of the Harwell Discharge PipelineRSRL IWS (Issue 5 – October 2012)6

NOT PROTECTIVELY MARKEDRSRL IWS (NDA/038/IWS)(Original numbers NDA/LTP(2008)P12/IWS and NDA/LTP(2008)P16/IWS)REVISION RECORD SHEETRSRL IWS Date Change(s) from Previous IssueIssue 5 25 October 2012 Incorporating comments following internal review. Checkedby Alan Fisher and approved by Tony Wratten.Issue 5 Draft 1 8 October 2012 Updated to reflect agreed changes to baseline and providedfor internal review.Issue 4 19 March 2012 Checked by Helen Thomason and Alan Fisher. Approvedby Alan Neal.Issue 4 Draft 2 15 March 2012 Incorporating comments from A Neal, H Thomason,A Fisher, R Lightowlers, G StonellIssue 4 Draft 1 5 March 2012 Updated to reflect agreed changes to baseline and providedfor internal review.Issue 3 15 March 2011 Checked by Helen Thomason and Sam CoxIssue 3 Draft 2 8 March 2011 Incorporating comments from A Inns, P Atyeo, C Colyer,B Smith, E Abel, R LightowlersIssue 3 Draft 110 February2011Updated to reflect agreed changes to baseline and providedfor internal review.Issue 2 24 March 2010 Checked by Helen ThomasonIssue 2 Draft 2 22 March 2010 Checked by Sam CoxIssue 2 Draft 1 10 March 2010 Update of IWS to underpin LTP Baseline March 2010 withchanges since LTP 2008 Rev D – Issue for commentIssue 1 3 March 2009 Incorporated comments from Gary Preston and HelenThomason. Issued with LTP08 Rev D submission to NDAIssue 1 Draft 2 26 Feb 2009 Incorporated comments from John Almon and Ken HeiderIssue 1 Draft 1 13 Feb 2009 Harwell and Winfrith IWS documents amalgamated into onedocument following combination of sites into singlelicensee, Research Sites Restoration Limited (RSRL) on 2February 2009.RSRL IWS (Issue 5 – October 2012)7

NOT PROTECTIVELY MARKEDContents1 EXECUTIVE SUMMARY 22 INTRODUCTION 112.1 Background 122.1.1 Harwell 132.1.2 Winfrith 142.2 RSRL Objectives 162.3 Significant Changes from Previous Version of IWS 173 WASTE MANAGEMENT POLICY, ORGANISATION & ARRANGEMENTS 183.1 Statement of Policy and Principles 183.1.1 Principles of Waste Management at RSRL 183.1.2 RSRL Approach to Waste Minimisation and Waste Hierarchy 193.1.3 RSRL Approach to Sustainable Development 203.1.4 Recent Developments in Policy, Regulations, and Requirements 203.1.5 Local Waste Management Plans 233.1.6 Good Practice Guidance Used by RSRL 243.2 Waste Management Organisation 243.3 Waste Management Arrangements 263.3.1 Accreditation Status 263.3.2 Overview of the RSRL Integrated Management System 263.3.3 Waste Management Requirements and the Waste Hierarchy 293.3.4 Good Practice and Research & Development 313.3.5 Skills, Records and Interfaces with Other Sites 324 INTEGRATED WASTE MANAGEMENT STRATEGY 334.1 Methodology for Strategic Option Studies 334.1.1 Option Studies 344.1.2 Decommissioning Strategy and Studies 344.2 Site Prioritisation Logic 354.3 Waste Management Constraints and Dependencies 374.3.1 Regulatory Constraints and Dependencies 374.3.2 Financial Constraints and Dependencies 374.3.3 Timing Constraints and Dependencies 374.3.4 Technical Constraints and Dependencies 384.3.5 Constraints and Dependencies 384.3.6 Key Site Specific Constraints and Dependencies 384.4 Site End Points and Contaminated Land / Groundwater 394.4.1 Harwell 394.4.2 Winfrith 404.5 Assumptions, Exclusions, Risks and Opportunities 414.5.1 Key Assumptions 414.5.2 Risks and Opportunities 444.5.3 Interactions with other Sites or Organisations 484.6 Stakeholder Engagement 495 OVERVIEW OF SITE WASTE STRATEGY 525.1 Harwell 535.2 Winfrith 566 HARWELL INTEGRATED WASTE MANAGEMENT STRATEGY 596.1 Radioactive Wastes 606.1.1 High Level Waste 606.1.2 Intermediate Level Waste 60RSRL IWS (Issue 5 – October 2012)8

NOT PROTECTIVELY MARKED6.1.3 Low Level Waste 686.2 Radioactive Discharges 726.2.1 Radioactive Liquid Discharges 726.2.2 Radioactive Gaseous Discharges 756.3 Non-Radioactive Wastes and Exempt (‘Out of Scope’) Wastes 766.3.1 Hazardous Non-Radioactive Waste 766.3.2 Non-Hazardous Non-Radioactive Waste 776.3.3 Inert Non-Radioactive Waste 786.3.4 Non-Radioactive Discharges 806.4 Waste Disposal and Transfer Routes 806.5 Tenant and Third Party Waste 807 WINFRITH INTEGRATED WASTE MANAGEMENT STRATEGY 827.1 Radioactive Wastes 827.1.1 High Level Waste 827.1.2 Intermediate Level Waste 837.1.3 Low Level Waste 867.1.4 Other Solid Radioactive Waste 907.2 Radioactive Discharges 907.2.1 Liquid Discharges 907.2.2 Gaseous Discharges 957.3 Non-Radioactive Wastes and Exempt (‘Out of Scope’) Wastes 957.3.1 Hazardous Non-Radioactive Wastes 967.3.2 Non-Hazardous Non-Radioactive Wastes 967.3.3 Inert Non-Radioactive Wastes 967.3.4 Non-Radioactive Discharges 987.4 Waste Disposal and Transfer Routes 988 AREAS REQUIRING FURTHER DEVELOPMENT & ACTION PLAN 1009 CONCLUSIONS 104ANNEX LIST 106ANNEX 1: WASTE DATA TABLES (RESTRICTED) 107ANNEX 2: AUTHORISED RADIOACTIVE WASTE TYPES AND DISPOSAL ROUTES 108ANNEX 3: REGULATORY CONSTRAINTS AND DEPENDENCIES 110ANNEX 4: GLOSSARY AND ACRONYMS 117RSRL IWS (Issue 5 – October 2012)9

NOT PROTECTIVELY MARKEDFiguresFigure 1: Waste Management Hierarchy.................................................................................... 20Figure 2: RSRL Organisation Chart Relating to Waste Management ........................................ 25Figure 3: RWS Group Interactions ............................................................................................. 26Figure 4: RSRL Management System........................................................................................ 27Figure 5: The RSRL Waste Management Process .................................................................... 28Figure 6: Harwell ILW Strategy ..................................................................................................67Figure 7: Harwell LLW Strategy ................................................................................................. 71Figure 8: Harwell Liquid Waste Strategy .................................................................................... 74Figure 9: Harwell Non-radioactive Waste Strategy .................................................................... 79Figure 10: Winfrith ILW Strategy ................................................................................................85Figure 11: Winfrith LLW Strategy ............................................................................................... 89Figure 12: Winfrith Liquid Waste Strategy.................................................................................. 94Figure 13: Winfrith Non-radioactive Waste Strategy .................................................................. 97RSRL IWS (Issue 5 – October 2012)10

NOT PROTECTIVELY MARKED2 INTRODUCTION16. The Harwell site in Oxfordshire and the Winfrith site in Dorset are managed together as oneSite Licence Company (SLC) known as Research Sites Restoration Limited (RSRL).17. NDA requires all its sites to produce and implement an optimised Integrated Waste Strategy(IWS) to the specification ENG01, Rev 2, 2 August 2006. The RSRL IWS documentoutlines the current strategy for managing the radioactive and non-radioactive waste on theHarwell and Winfrith sites and supports the waste strategy in the latest RSRL Lifetime Plan.A site waste Best Practicable Environmental Option (BPEO) study was completed in 2008for Harwell and 2006 for Winfrith. As a result of these studies a fully optimised IWS wasdeveloped in 2010 for all wastes on the sites.18. The overall objective of the IWS is to demonstrate how RSRL will assess and manage allradioactive and non-radioactive wastes (including those in solid, liquid or gaseous form)arising from the site’s past, present and future operations and any other waste transferredfrom other sites for management or disposal.19. The strategy demonstrates that the waste can be appropriately managed in accordance withthe requirements of the ‘Best Practicable Environmental Option’ (BPEO) and ‘BestPracticable Means’ (BPM) methodologies 3 . It enables RSRL to demonstrate to regulatorsand stakeholders, the proper control of wastes in the timeframe and at the rate at which theyarise.20. The Site Waste Management Plans Regulations 2008 require construction sites to producea plan that details the amount and type of waste that will be produced and how it will bereused, recycled, or disposed of. The plan is updated during the construction or demolitionprocess to record how the waste is managed and to confirm the disposal of any materialsthat cannot be reused or recycled at a legitimate site. RSRL procedure PRC0199 requiresprojects to complete a Site Waste Management Plan (SWMP) for each project with a valuein excess of £300k. The RSRL IWS is used to complement the detailed given by projectSWMPs.21. In September 2011, RSRL, in collaboration with the national Low Level Waste Repository(LLWR), issued a joint LLW Management Plan. The plan is a proactive document to assistin implementing the UK LLW Strategy. RSRL has made significant progress in seekingalternatives to direct disposal of waste to LLWR by actively developing routes for thedisposal of LLW and HV-LLW to off-site landfill. RSRL also continues to develop alternativeroutes for the treatment of segregated metals and combustible materials.22. During 2011, RSRL and LLW conducted a joint review of options for making RSRL’sdecontamination service at Winfrith available to other nuclear operations and concluded thatthere was already sufficient capacity to adequately serve the nuclear industry at that time.This position was reviewed in June 2012 with the same conclusion. There is scope forfurther alignment of RSRLs activies with the National Strategy and RSRL continues to workcollaboratively with LLWR and other SLCs to develop best practice arrangements in wastemanagement.3The Environmental Permitting Regulations 2010 have since superseded BPEO (and Best PracticableMeans (BPM)) with Best Available Technique (BAT)RSRL IWS (Issue 5 – October 2012)11

NOT PROTECTIVELY MARKED2.1 Background23. The Harwell and Winfrith sites are two former UK Atomic Energy Authority nuclear researchsites which have been undergoing decommissioning and restoration since the early 1990s.The UK Atomic Energy Authority continued to manage the decommissioning, on behalf ofthe NDA from its formation in April 2005, but was restructured to allow the NDA to competethe management of these sites in the future. Research Sites Restoration Limited wasformed to manage the newly combined Harwell and Winfrith sites for the NDA andcommenced operation on 2 February 2009.24. RSRL is now a wholly-owned subsidiary of Babcock International Group PLC and operatesunder contract to the NDA. RSRL holds the nuclear site licences, discharge permits andother regulatory approvals necessary to operate the Harwell and Winfrith sites. The contractfrom the NDA for the management and operation of these sites has been transferred toRSRL pending competition for the ownership of RSRL.25. The Harwell and Winfrith sites already had a close working relationship prior to the formationof RSRL due to their similar histories, challenges and relative geographical proximity.Shadow working started in 2008 under a single management structure with the site plansand management systems becoming progressively integrated. The site programmesincluding scope, schedule and costs were first submitted to NDA as one plan under acombined Lifetime Plan in March 2008 and a single IWS document was first produced in2009.26. The Harwell site covers 300 hectares and is located in Oxfordshire within an Area ofOutstanding Natural Beauty. The current status of the NDA designated area is that it isoperated by RSRL and forms part of Harwell Oxford Campus, a major science, technologyand business centre employing around 4,500 people.27. The Winfrith site is located in Dorset and includes a mixture of active and inactive buildingson the 81 hectare nuclear licensed site. It also includes some undeveloped land thatoverlaps historic heathland with SSSI (Site of Special Scientific Interest) status and isdesignated as a Special Area for Conservation. Over 180 hectares of surplus land has beenprogressively sold off in recent years to English Partnerships which manages the adjacentland as a major regional science and technology centre employing over 1,000 people.28. The objective of RSRL’s decommissioning programme is to release land and facilities foreither new commercial development as part of Harwell Oxford Campus and the TechnologyCentre at Winfrith or for open heathland at Winfrith. This will ensure that a valuable legacyis developed and maintained as the nuclear liabilities are removed. Both sites will beprogressively delicensed until their future status as a fully delicensed site, unrestricted byany nuclear site licence conditions, is achieved. RSRL will then ask NDA for the sites to beremoved from their list of designated sites so that they can be transferred to their end stateuse.29. The current assumed final site end state for the Harwell site is defined as a fully delicensedsite. However it is expected that there will still be permits from the Environment Agency(EA) in place for the Western Storage Area. For Winfrith the assumed end state is a fullydelicensed site which is free from any Authorisations and Permits from the EA. The historyof the RSRL sites and the facilities relevant to the waste strategy are described below.RSRL IWS (Issue 5 – October 2012)12

NOT PROTECTIVELY MARKED2.1.1 Harwell30. The Harwell site was originally an RAF station and became Britain’s Atomic EnergyResearch Establishment in 1946. Most of the nuclear reactors, laboratories, workshops andother support facilities were built in the late 1940s, 1950s and 1960s and many of them werebased in buildings constructed by the RAF. Major nuclear research facilities continued tooperate on the Harwell site until the 1990s. Since then a programme of work has been inprogress with the objective of safely decommissioning and dismantling the redundantfacilities and safely managing radioactive wastes, both legacy wastes already in stock andthose generated during decommissioning.31. The key facilities relevant to the integrated waste strategy at Harwell include the SolidWaste Complex, the Active Handling Facility, the Radiochemical Building and the LiquidEffluent Treatment Plant (LETP).• The Solid Waste Complex includes stores for Remote Handled Intermediate LevelWaste (RHILW), Contact Handled Intermediate Level Waste (CHILW) and ConcreteLined Drums (CLDs). It also includes facilities for retrieval, processing andrepacking RHILW and a processing / packing area for CHILW and LLW operations,including decontamination. A Waste Encapsulation Plant (WEP) has beenconstructed in the Solid Waste Complex, which is currently undergoing inactivecommissioning. This plant will be used to make RHILW passively safe byencapsulating the waste in 500-litre drum with cement. It is expected to beginoperations in 2014.• The Active Handling Facility was previously used for post-irradiation examinationwork and consists of two concrete cell lines which have been used for segregation,size reduction and treatment of RHILW before it is packaged in the Solid WasteComplex. In parallel with the processing of third party sources, initial post-operationclean-out (POCO) of the cell lines has been undertaken. Operations related to thirdparty work are planned to finish in 2013 after which final POCO will be carried outbefore placing the facility in Care & Maintenance until 2020.• The Radiochemical Building consists of an interim CHILW store and a stainless steellined cell-line which has recently completed a package of work to treat RHILW beforebeing packaged in the Solid Waste Complex. The facility is now in a phase of Care& Maintenance until decommissioning commences in 2021.• The LETP consists of legacy sludges stored in tanks, a plant for immobilising thelegacy sludges, facilities for the treatment of operational liquid effluent and thestorage / conditioning of the resulting operational sludges.32. Decommissioning of the New Main Active Drain (NMAD) system, used to carry low levelliquid effluent from the major facilities on the Harwell site to the Liquid Effluent TreatmentPlant (LETP), was completed during 2011/12.33. The strategy for waste is mainly influenced by the volumes of legacy ILW stored at Harwellarising from operations throughout the life of the site. Legacy wastes include:• RHILW and ex-reactor fuel in tube stores• Nuclear material and ex-National Disposal Service (NDS) sources in shieldedstorage• CHILW and concrete lined drums in unshielded storage• Sludges in tanks34. RSRL has several wastes which contain Nuclear Materials (NM) that have arisen as a resultof the research and development programmes carried out on both RSRL’s Harwell andRSRL IWS (Issue 5 – October 2012)13

NOT PROTECTIVELY MARKEDWinfrith sites in support of the UK Civil nuclear power programme. These wastes arecurrently stored on the Harwell site. An agreement has been reached to transfer this NM toSellafield for onward processing and long-term storage pending final disposal to a futureGeological Disposal Facility (GDF). This is in line with current NDA Strategy (effective April2011) which encourages the optimisation of waste management solutions by using assetsacross the NDA estate.35. The strategy is to convert all remaining historic arisings into a passively safe form by 2023.The current storage locations for many of these wastes need to be emptied beforedecommissioning can commence. Future arisings range from ILW and LLW through tohazardous and non-hazardous exempt (‘out of scope’) waste. These wastes will beproduced during the decommissioning of the reactors, waste management facilities andbuildings containing low or no activity. The previous operations of these facilities andbuildings are relevant to the decommissioning and waste management strategies todecommission the individual facilities.36. The Harwell site strategy is to package all ILW into final disposal packages anddecommission all redundant facilities, except for the Shielded Vault Store, the WasteEncapsulation Plant, the new Harwell ILW Store and some facilities in the Solid WasteComplex, by 2032. Much of the site will have been de-licensed and other areas will beready to be de-licensed by the ONR. LA-LLW and HV-VLLW suitable for landfill will havebeen transferred to an off-site disposal facility and the WSA Groundwater Containment Plantoperations will have ceased.37. By the Final End State in 2050, all the ILW will have been transferred to the GeologicalDisposal Facility (GDF), the stores and remaining facilities in the Solid Waste Complex willhave been decommissioned, all redundant buildings demolished and all the remaining landremediated and de-licensed38. RSRL has developed the current LTP baseline which includes the strategy and strategicassumptions for the Harwell site. The resulting key decommissioning milestones are:MilestoneKey MilestoneCompletion DateLETP Buildings and Tanks decommissioned 2016Radiochemical Building decommissioned 2029Active Handling Facility decommissioned 2027MTRs Decommissioned 2032Solid Waste Complex decommissioned 2049Final End State (whole site delicensed) 20502.1.2 Winfrith39. In 1957 Winfrith carried out research and development into electricity generation fromnuclear power. Eight reactors were operational on the site including the Steam GeneratingHeavy Water Reactor (SGHWR), the DRAGON and ZEBRA reactors, and five other zeroenergy and low power reactors. The site also had nuclear fuel manufacture andexamination facilities, plutonium laboratories, nuclear waste treatment and storage facilities,various experimental laboratories, effluent treatment facilities and a sea discharge pipeline,together with offices and workshops.RSRL IWS (Issue 5 – October 2012)14

NOT PROTECTIVELY MARKED40. During the 1990s, the Government ended reactor research and this led to the start of thesite decommissioning programme and the development of other non-nuclear areas ofscientific and technical research. The last operational reactor closed at Winfrith in 1995.41. The ZEBRA reactor was decommissioned and demolished during 2005/6, while theSGHWR and DRAGON reactors have been de-fuelled and placed in care and maintenance.A number of ancillary facilities have been successfully decommissioned including fiveresearch reactors, Plutonium Facilities, Analytical and Chemical Laboratories, a ChemistryLaboratory, Health Physics Laboratories, a Chemical Cleaning Building, the Fissile MaterialStore and the Active Handling Facility.42. During 2011, the decommissioning of 597 fission chambers and a number of reactor tanksfrom DRAGON was undertaken. The tanks were successfully size-reduced using the tanksthemselves as their own containment and using hot cutting methods.43. The Winfrith EAST Treatment Plant (WETP) which was used for the processing andencapsulation of legacy sludges arising from historic SGHWR operations was successfullydecommissioned and demolished during 2011/12. Since beginning operations in 2005 morethan 1,000 drums of sludge were processed through the plant and sent for storage in theTreated Radwaste Store pending disposal to LLWR.44. Following a five year programme, the SGHWR External Active Sludge Tank (EAST) hasbeen emptied of sludge and heels and the tanks decommissioned. The next phase of workis to remove the tank base and sub-base ensuring that waste is segregated for disposal tothe appropriate route. It is envisaged that the majority of the waste from the bases will beeither VLLW or LA-LLW with a minimal volume being disposed to LLWR.45. During 2012 the NDA asked Babcock to provide reach-back support through RSRL todevelop an underpinned programme level business case for early closure of the Winfrithsite. The programme of work included development of technical and waste managementmethodologies; underpinning schedule and cost data; and associated stakeholder andimplementation management plans. The outcome of this review has been considered andthe changes included in this version of the IWS.46. The main waste arisings remaining to be dealt with on the Winfrith site are the result ofhistoric waste and fuel operations and those expected to arise from future decommissioningoperations.47. The key facilities and operations relevant to the integrated waste strategy at Winfrith are theTreated Radwaste Store (TRS) and LLW Operations:• Drums of encapsulated SGHWR sludge are stored in the TRS pending off-sitedisposal to LLWR.• The LLW processing capability was moved from A58 to SGHWR in 2008. LLW issupercompacted (where possible) and packaged into HHISOs for transfer to theLLWR.48. The Winfrith site strategy is for conversion of historic arisings to a passively safe form by2021 and transfer of all ILW packages to Harwell for long-term storage by 2022. Reactorswill be progressively decommissioned by 2023, enabling the site to achieve an interim endstate by 2024.49. Prior to development of the Winfrith Optimised Plan the strategic assumption was that ILWarising from decommissioning of the Winfrith site would be stored on-site pending directRSRL IWS (Issue 5 – October 2012)15

NOT PROTECTIVELY MARKEDtransfer to the GDF after 2040. Due to the shortened timescales for the decommissioning ofthe Winfrith site the strategy has now been changed to transferring the ILW from Winfrith toHarwell for interim storage in the Harwell ILW Store before consignment from Harwell to theGDF.50. RSRL has developed its LTP baseline which identifies the strategy and strategicassumptions for the Winfrith site. The key resulting decommissioning milestones are:MilestoneKey MilestoneCompletion DateDRAGON decommissioned and demolished 2021SGHWR decommissioned and demolished 2023ILW packages transferred to Harwell 2022Interim End State 20242.2 RSRL Objectives51. RSRL’s objectives are to maintain high standards of safety, security and environmentalperformance whilst eliminating the nuclear liabilities at the lowest lifetime costs. Funding isused to ensure safety and compliance with the Nuclear Site Licence, environmentallegislation, and security requirements, whilst undertaking a programme of hazard reduction.Expenditure is prioritised in line with the NDA prioritisation process (EGPR02) and theannual site funding limit.52. This Integrated Waste Strategy demonstrates how RSRL will assess and manageradioactive and non-radioactive wastes at its sites. It includes legacy wastes which havealready arisen, material that will become waste during decommissioning, and authoriseddischarges of liquid or gaseous waste to the environment. The waste hierarchy upon whichthe IWS is based aims to minimise waste generation and encourage recycling and reuse aspart of the disposal process. The overall strategy for wastes is to sort the waste to thelowest hazard or activity category, to make full use of available waste disposal routes, andmake waste passively safe for long term storage where disposal routes are currently notavailable.53. The Integrated Waste Strategy will support delivery of:• Progressive hazard reduction• Treatment and repackaging of historic arisings of waste• Managing waste in a safe and cost effective manner, including waste minimisation• Infrastructure cost reduction• Decommissioning of reactors, waste management facilities and minor facilities• Remediation of contaminated land• De-licensing of the site following decommissioning and remediation• Disposal of areas once the restoration work is complete.RSRL IWS (Issue 5 – October 2012)16

NOT PROTECTIVELY MARKED2.3 Significant Changes from Previous Version of IWS54. Key approved baseline changes in the Harwell strategy include:• The use of Robust Concrete Boxes for the disposal of Harwell reactorsdecommissioning ILW rather than 2 metre boxes.• The receipt of packaged Winfrith ILW for interim storage pending disposal to theGDF.• The re-categorisation of some LETP Low Level legacy sludges from LLW to ILW.These sludges have been encapsulated and will remain in interim storage in theSolid Waste Complex pending final disposal to the GDF.55. During 2012 the NDA asked Babcock to provide reach-back support through RSRL todevelop an underpinned programme level business case for early closure of the Winfrithsite. The programme of work included development of technical and waste managementmethodologies; underpinning schedule and cost data; and associated stakeholder andimplementation management plans. The outcome of this review has been considered andthe key approved baseline change in the Winfrith strategy are:• The use of Robust Concrete Boxes for the disposal of Winfrith decommissioning ILWrather than 2 metre boxes• The transfer of Robust Concrete Boxes containing grouted Winfrith ILW to theproposed Harwell ILW for interim storage pending disposal to the GDF• The deletion of scope, schedule and costs for design, build and commissioning of anew ILW store at Winfrith• The transfer of Winfrith thorium metal to Harwell for interim storage pendingpackaging and disposal to the GDF. An opportunity to return it to the fuel cycle isbeing pursued• The transfer of encapsulated SGHWR sludges, currently stored in the TRS atWinfrith, to the Low Level Waste Repository rather than the GDFRSRL IWS (Issue 5 – October 2012)17

NOT PROTECTIVELY MARKED3 WASTE MANAGEMENT POLICY, ORGANISATION &ARRANGEMENTS56. This section outlines the regulatory and policy framework against which the RSRL IWS hasbeen developed, along with the organisation and management arrangements for wasteswhich ensure compliance with this framework.3.1 Statement of Policy and Principles3.1.1 Principles of Waste Management at RSRL57. An overview of the Government policy, legislation and regulatory requirements relevant towaste management and disposal is given in Section 4.3 and Annex 3 to this IWS. Furtherdetails are provided in the Companion Document to the Integrated Waste StrategySpecification (ENG02, Rev 2, 2 August 2006).58. NDA considers that the following principles should underpin waste strategy [Source NDAIntegrated Waste Management Overview December 2009]:i) Give priority to reducing risk by retrieval and immobilisation of potentially mobilehistorical wastes stored on NDA sites;ii) Support the core NDA principles of protecting safety, security and the environment, andvalue for money;iii) Apply the Waste Hierarchy:← preferred approachless preferred approach →● avoid ● minimise ● re-use ● recycle ● disposeiv) Drive for ‘early’ waste solutions rather than leaving waste liabilities un-addressed. Wastemanagement activities must be integrated with other activities and take account of thesustainability principles;v) Decide how to manage wastes on the basis of business cases that take account ofPrinciples 1 to 4;vi) Engage with our stakeholders about potential and actual developments in wastemanagement from earliest stages.59. In addition to these key principles the following principles of policy are also consideredapplicable to management of waste on the RSRL’s sites. These derive from a number ofGovernment policies including The Decommissioning of the UK Nuclear Industry's Facilities,September 2004 (DTI Publication URN 04/1598) and Review of Radioactive WasteManagement Policy (CM 2919, 1995) and the Energy Act direction to the NDA regardingdecommissioning and clean-up of the sites :• Protection of the public, workforce and environment (Cm 2919 Paragraph 51)through:o Keeping radiological doses and environmental impact as low as reasonablyachievable, ALARA (Cm 5552)o Converting waste into a passively safe state as soon as practicableRSRL IWS (Issue 5 – October 2012)18

NOT PROTECTIVELY MARKEDo Minimising discharges, e.g. through the use of best available technique (BAT) anddisposals• Strategic planning, taking account of local and regional waste management plans• Consideration of BAT in the selection of waste management options• Proximity principle (see glossary)• Sustainable development (see glossary)• Use of good practice guidance, such as the Nuclear Industry Code of Practice onClearance and Exemption.3.1.2 RSRL Approach to Waste Minimisation and Waste Hierarchy60. One of the key aspects of waste management at RSRL is to ensure that the production andaccumulation of new waste is minimised. This is encompassed within the NDA requirementfor the application of the principles of the Waste Hierarchy (see Figure 1) to bothradioactive and non-radioactive wastes. The waste hierarchy is intended to ensure thatminimal waste requires disposal and that planning fully addresses opportunities for avoidingwaste production, minimising waste volumes and making maximum reuse of materials andrecycling routes, in descending order of preference:• Waste Minimisation - the creation of waste is prevented or minimised at source asfar as practicable. Waste minimisation applies to both the quantity and hazardassociated with the waste. Every effort is made not to produce waste but where thisis unavoidable the volume of each type of waste produced is minimised wherepossible by segregation, limiting the spread of contamination, decontamination andvolume reduction. This applies to all stages of site operations, starting from plantdesign and including tight control of materials taken into active areas.• Reuse - where waste cannot be prevented or minimised, waste materials orproducts are reused if practicable. For example some items are reused directly ordecontaminated before reuse; crushed concrete is used to fill holes produced duringdecommissioning; and soil from site remediation is used for landscaping.• Recycle - waste materials are recycled where practicable. For example clean andexempt metals are recycled as scrap.• Disposal - only when all opportunities to avoid the production of waste, minimisethe volumes, reuse and recycle waste material are exhausted is disposal to theenvironment the chosen option.RSRL IWS (Issue 5 – October 2012)19

NOT PROTECTIVELY MARKEDFigure 1: Waste Management Hierarchy3.1.3 RSRL Approach to Sustainable Development61. Sustainable redevelopment principles require that there is no undue burden on futuregenerations. This will be accomplished by restoring the sites to a state that will enable themto be delicensed and released for future re-use. In addition, sustainability will be achievedduring decommissioning and remediation operations by the application of the wastemanagement hierarchy to the management of all wastes at Harwell and Winfrith. Issuesrelating to sustainability such as intergenerational equity were considered in the site wasteBPEO studies. Support and information will be obtained from the SD:SPUR network as theIWS and decommissioning plans are developed.3.1.4 Recent Developments in Policy, Regulations, and Requirements62. Since the production of the first RSRL combined IWS in 2009 there have been a number ofother developments in national policy, legislative, and regulatory requirements. The keyitems include:NDA Strategy Effective from April 201163. In March 2011, in accordance with the Energy Act 2004, the NDA published their revisedstrategy following an extensive review and period of consultation.[4] . It continues therequirement for an Integrated Waste Strategy for each SLC, with risk reduction andimplementation of the waste hierarchy the key priorities. The strategy is more flexible withrespect to sharing waste management infrastructure across the NDA estate. RSRL’sagreed strategy and opportunities are supported by this document.4 NDA Strategy – Published March 2011RSRL IWS (Issue 5 – October 2012)20

NOT PROTECTIVELY MARKEDNDA’s Strategic Management System (SMS)64. SLCs are required to adopt and comply with NDA’s strategy which is devolved throughNDA’s Strategic Management System (SMS). The SMS has a number of key themes andrelated topic areas relevant to the IWS in particular those covering Nuclear MaterialManagement, Spent Fuel Management and Integrated Waste Management. Since the 2009IWS, the NDA has developed Topic Strategies which are intended to inform the productionof SLC Site Strategic Specifications (SSS). The SSS define the strategic assumptions thatthe SLCs are required to adopt in compiling their LTPs and hence underpin the IWS.Review of Long-term Interim Storage of HAW65. The NDA published a review of interim storage of higher activity waste (HAW) within the UKin April 2009. This recommended that storage strategies should allow HAW to be storedsafely for 100 years or more and that all wastes being conditioned for long-term storage anddisposal should be supported by safety cases underpinned by an understanding of how theconditioned waste and waste containers will evolve over time. The NDA published a HigherActivity Waste Credible Options paper in February 2011 and completed a stakeholderengagement exercise. RSRL has worked with the NDA to develop options for ILW storagewithin RSRL and has implemented a change in strategy to transfer Winfrith ILW to Harwellfor long-term storage thereby negating the need to commission a new store at Winfrith andenabling early closure of the Winfrith site.Radioactive Waste Management Cases66. The concept of a “Radioactive Waste Management Case” (RWMC) was provided inguidance issued by EA, HSE and SEPA [5]. This evolved from the 2005 “Guidance on theConditioning of ILW on Nuclear Licensed Sites” [6] jointly issued by the regulators, whichintroduced the concept that waste producers should produce an ‘ILW Conditioning Proposal’as part of the Safety Case for a plant conditioning ILW. This would act as an overarchingdocument for the waste treatment route, bringing together the different suites of documentssuch as Safety Cases and Letters of Compliance to demonstrate both the acceptability ofthe product for disposal, and how the specific treatment route is justified for a particularwaste stream. This document had been updated and expanded [7] and further guidanceproduced on specific aspects: the content of RWMCs [8]; waste minimisation,characterisation and segregation [9]; conditioning and disposability [10], storage [11] andmanaging information [12].5“The Management of Radioactive Waste on Nuclear Licensed Sites, Part I The Regulatory Process”,HSE/EA/SEPA, December 2007.6“Conditioning of Intermediate Level Radioactive Waste on Nuclear Licensed Sites”, HSE/EA/SEPA,2005.7The Management of Higher Activity Radioactive Waste on Nuclear Licensed Sites, Joint guidancefrom the Health and Safety Executive, the Environment Agency and the Scottish EnvironmentProtection Agency to nuclear licensees, Issued Feb 2010 (Overview and 6 supporting documents)8“The Management of Radioactive Waste on Nuclear Licensed Sites, Part 2 Radioactive wastemanagement cases”, HSE/EA/SEPA, February 2010.9“The Management of Radioactive Waste on Nuclear Licensed Sites, Part 3A Waste minimisation,characterisation and segregation”, HSE/EA/SEPA, February 2010.10 “The Management of Radioactive Waste on Nuclear Licensed Sites, Part 3B Conditioning andDisposability”, HSE/EA/SEPA, February 2010.11 “The Management of Radioactive Waste on Nuclear Licensed Sites, Part 3C Storage of RadioactiveWaste”, HSE/EA/SEPA, February 2010.12 “The Management of Radioactive Waste on Nuclear Licensed Sites, Part 3D Managing informationrelating to radioactive waste”, HSE/EA/SEPA, February 2010.RSRL IWS (Issue 5 – October 2012)21

NOT PROTECTIVELY MARKED67. Effectively, if the guidance is followed, it is expected that the RWMC will demonstratecompliance with the law as interpreted by the regulators at the time of writing of theguidance. Traditional safety cases focus on the safety of an individual plant to conduct itsmission whilst an RWMC is intended to focus on the waste material(s) that may beprocessed through multiple plants that each has their own safety case. The guidancesuggests that the RWMC brings together various considerations including:• BAT• The impact that management of this waste stream may have on the plant, process,site safety and environment;• Proposals for storage and monitoring of waste condition;• Arrangements for preservation of data relating to this waste stream;• Integrated Waste Strategies;• Disposability of the Product.68. Whilst the RWMC may be considered part of the conventional safety case for wastemanagement facilities, many such plants became operational or waste conditioning planswere developed before it was a requirement. In such cases the RWMC needs to beproduced retrospectively; the guidance suggests that review of an RWMC should beundertaken alongside the periodic review of related plant Safety Cases. RSRL issystematically producing RWMCs for each of the relevant waste streams. The RWMCs arereviewed by the Waste Strategy team and relevant project managers. They are kept as partof the appropriate project file and can be made available to RWMD, HSE and EA asrequired.Best Available Technique (BAT) Assessments69. The Statutory Guidance requires the Environment Agency to base its regulatory decisions inrelation to discharges of radioactive waste into the environment on the principles set out inthe 2009 UK Strategy. These principles include the use of BAT as the means the operatoruses to achieve an optimised outcome. The term BAT means the latest stage ofdevelopment (state of the art) of processes, of facilities or of methods of operation whichindicate the practical suitability of a particular measure for limiting discharges, emissionsand waste. The use of BAT replaces “best practicable means” (BPM) and “best practicableenvironmental option“(BPEO), and is expected to deliver the equivalent level ofenvironmental protection as achieved previously by the use of BPM and BPEO.70. RSRL has recently undertaken high-level strategic BAT reviews for metallic LLW, WinfrithLA-LLW / VLLW and “soft-solid” LLW (formerly this was referred to as “combustible LLW”however as there are a number of treatment options available for this type of secondarywaste the term “combustible” LLW is no longer appropriate). These reviews includedreassessment of the underlying assumptions and decisions taken at the time of the originalBPEO studies. A representative from LLWR Ltd attended each of the reviews.Radioactive Low Level Waste (LLW) Policy71. In March 2007 the Government published the policy 13 for the long term management of solidlow level radioactive waste. The overall aim of the policy was to set out the need for greaterflexibility in managing LLW and set out a number of requirements for the NDA includingdevelopment of a UK nuclear industry LLW strategy and developing a plan for the optimumuse of LLWR. Following a period of consultation, NDA issued the UK Strategy for theManagement of Solid LLW for the Nuclear Industry in August 2010. The strategy13 Policy for the Long Term Management of Solid Low Level Radioactive Waste in the UKRSRL IWS (Issue 5 – October 2012)22

NOT PROTECTIVELY MARKEDimplements the Government policy and aims to provide a high level framework within whichLLW management decisions can be taken to ensure safe, environmentally acceptable andcost-effective management solutions.72. The Government policy included revised regulation around the disposal of LLW to landfill.This means the nuclear industry can now dispose of HV-VLLW (a new sub-category of LLW)to landfill.73. Landfill companies and nuclear operators have to apply to the Environment Agency (EA) forpermits to receive and dispose of low level radioactive waste.74. RSRL is represented at the LLW Steering Group which continues to take forward the UKwidestrategy for managing LLW for the NDA and hence maintains awareness ofdevelopments which may impact on the management of LLW at the RSRL sites.3.1.5 Local Waste Management Plans75. RSRL strategic planning for the management of its wastes takes account of local andregional waste management plans.76. For Harwell, current planning policy for minerals and waste is contained in the OxfordshireStructure Plan 2016 and the Oxfordshire Minerals and Waste Local Plan.77. The Minerals and Waste Local Plan was adopted in July 1996 and covered the period to2006. It will be replaced by a new style Minerals and Waste Plan which is currently underdevelopment. This will be made up of a number of documents and will provide up to datemineral and waste planning policy for the period up to 2030.78. Under the Planning and Compulsory Purchase Act 2004, policies in existing Local Planswere 'saved' for three years, to 27 September 2007, when they would expire unless theSecretary of State agreed to 'save' them beyond that date. To avoid a gap in planningpolicy for minerals and waste development pending preparation of the Minerals and WasteDevelopment Framework, the Secretary of State issued a Direction on 25 September 2007that 46 policies in the Minerals and Waste Local Plan continue to be 'saved'.79. For Winfrith, the Bournemouth, Dorset and Poole Waste Local Plan (WLP), adopted in June2006, is the current development plan document for waste developments. The WLPprovides guidance and criteria when considering waste planning applications and sets out anumber of key objectives aimed at promoting sustainable waste management. The WLPwill also be replaced by the new style Minerals and Waste Plan currently underdevelopment.80. The RSRL IWS aims to comply with these objectives and guiding principles of the WLPwhich are:• Best Practical Environmental Option (now BAT)• Self-sufficiency• The Proximity Principle• The Waste Hierarchy.RSRL IWS (Issue 5 – October 2012)23

NOT PROTECTIVELY MARKED3.1.6 Good Practice Guidance Used by RSRL81. Guidance on good practice and general advice on waste management is taken from avariety of sources by RSRL and includes the following:• ‘Nuclear Industry Code of Practice for Clearance and Exemption’ – providesguidance on how to measure and assess waste in order to dispose of waste asexempt (‘out of scope’) or non-radioactive• SAFEGROUNDS – Good practice guidance for the management of contaminatedland and defence sites• SD:SPUR – Site Decommissioning: Sustainable Practices in the Use of Resources• HSE, EA and SEPA – The Management of Higher Activity Radioactive Waste onNuclear Licensed Sites, Joint guidance from the Health and Safety Executive, theEnvironment Agency and the Scottish Environment Protection Agency to nuclearlicensees, Issued Feb 2010 (Overview and 6 supporting documents)• Radioactive Substances Regulation (RSR): Principles of optimisation in themanagement and disposal of radioactive waste.• EA Pollution Prevention Guidance (PPG) notes• EA Requirements Working Group, EARWG, which was established as a BestPractice Forum for radioactive waste and manages the production of a best practicewebsite including a waste minimisation database3.2 Waste Management Organisation82. The Harwell and Winfrith sites became one site licensee company (SLC) known asResearch Sites Restoration Limited (RSRL) in February 2009. The RSRL wastemanagement organisation, as shown in Figure 2, comprises the management team whichreports to the Managing Director of RSRL and includes the following:• The Harwell Closure Director has overall responsibility for the strategicdevelopment, implementation, operation and decommissioning of the Harwell site• The Winfrith Closure Director has overall responsibility for the strategicdevelopment, implementation, operation and decommissioning of the Winfrith site• The Waste Strategy Manager has responsibility for developing waste managementstrategy including the production of the IWS, ensuring that appropriate technicalwork and option studies are undertaken to support the development of the IWS• The Environment Manager has responsibility for managing the site waste BestAvailable Technique (BAT ) studies which will support the IWS and futureapplications for EPR2010 Permits.• The Solid Waste Complex Project Manager and Senior Project Managers haveresponsibility for implementing the waste management strategy• The Waste Compliance Manager and Assistant Waste Compliance Managers(solid waste), the LETP Manager (liquid waste) and the Environment Manager(gaseous waste) have responsibility for applying the Waste Hierarchy and BestAvailable Technique (BAT) for waste minimisation, and compliance with permits andconditions for acceptance.• Project Managers, Authority to Operate (ATO) Holders, and Area WasteOfficers (AWO) have direct responsibility for waste management within their projector area of work including the application of the waste hierarchy, waste minimisation,and compliance with permit requirements.RSRL IWS (Issue 5 – October 2012)24

NOT PROTECTIVELY MARKEDRSRL ManagingDirectorHarwell ClosureDirectorProgrammeDirectorSafety &EnvironmentDirectorCommercialDirectorWinfrith ClosureDirectorSenior ProjectManagersSolid WasteComplex ProjectManagerEnvironmentManagerWaste Policy &ComplianceManagerSenior ProjectManagersWaste StrategyManagerFigure 2: RSRL Organisation Chart Relating to Waste Management83. Key formal meetings that cover issues relating to waste management and wasteminimisation include the following:RSRL ExCom - a regular meeting of the RSRL directors, chaired by the ManagingDirector, makes executive decisions on the management of the Harwell and Winfrithsites. This includes matters relating to the site strategy, safety and environmental issuesas well as waste issues and funding.RWSG - the quarterly RSRL Waste Strategy Group chaired by the Waste StrategyManager, is the forum for developing waste management strategy and, whereappropriate, reviews documents such as the IWS and the site waste BAT studies.Changes to the technical baseline and waste strategy are not ratified at this meeting butare subject to change control through the RSRL programme management processesand governance arrangements set down in RSRL’s Procedure, PRC 0020, Sanctionsand Validation of RSRL’s Work Activities. Figure 3 shows the interactions of this groupwith the site strategy, permits and other waste related functions.RSRL IWS (Issue 5 – October 2012)25

NOT PROTECTIVELY MARKEDInteractions with RSRL Waste Strategy GroupRSRLExComSiteStrategyClosureDirectorsRegulatorInteractionEnvironmentalPermit(EPR2010)RWSGIntegratedWaste StrategyBEPO/BATStudiesTBuRD(R&Dneeds)RSRLLTPNDA mtgs;*NWRF; WPLM;WasteInventoryHazard Baseline;Hazard ReductionPlan; Prioritisation;Waste InventoryForm; ProcessWiring Diagrams*NWRF: Nuclear Waste Research Forum (including sub-groups);WPLM: Waste Packagers Liaison Meeting;Figure 3: RWS Group Interactions3.3 Waste Management Arrangements3.3.1 Accreditation Status84. To ensure that the requirements of relevant legislation and RSRL policies are achieved,Harwell and Winfrith operate integrated management systems which satisfies therequirements of the international standards: IAEA 50-C/SG-G; BS EN ISO9001:2000 andISO14001:2004. These cover the health, safety and environmental arrangements requiredof the sites.3.3.2 Overview of the RSRL Integrated Management System85. The RSRL management system (Figure 4) is designed to support the various processesundertaken on its sites. These are divided into strategy and management processes,enabling processes and support services. The enabling processes include the wastemanagement process which describes how RSRL manages its radioactive, non-radioactiveRSRL IWS (Issue 5 – October 2012)26

NOT PROTECTIVELY MARKEDwaste and nuclear materials destined to be waste. The system was updated in July 2010following a review against business need and best practice.Figure 4: RSRL Management System86. The RSRL Waste Management Process is summarised in Figure 5 and aims to ensure:• The consistent preparation and endorsement of waste management strategies at theHarwell and Winfrith sites• Consistent standards are applied in implementing these strategies• Compliance with legislative requirements and Conditions of Acceptance• Regular reviews of waste management are undertaken including reviewing theeffectiveness of arrangementsRSRL IWS (Issue 5 – October 2012)27

NOT PROTECTIVELY MARKEDFigure 5: The RSRL Waste Management Process87. The documented management system is designed to support the management of thevarious processes, including waste, and is available through the RSRL intranet. Themanagement system comprises three tiers of documentation:• Strategic processes encompassing strategic direction, governance, stakeholderengagement, management system maintenance, independent assessment andbusiness improvement• Delivery processes encompassing asset management, workforce and skillsmanagement, design, commissioning and decommissioning.• Support processes that are used by either delivery or strategic processes:• Safety Case• Safety Management (Ops)• Radiological Protection• Environmental Management• Work Control• SHE Risk Assessment• Tenant Control• Transport• Nuclear Materials Management• Asset Care & Maintenance• Self-Monitoring• Emergency PlanningRSRL IWS (Issue 5 – October 2012)28

NOT PROTECTIVELY MARKED• Non-conformance Management• Procurement• Manage People• Organisational Change control• Manage Security• Document Control• Knowledge Management88. The site ensures continual improvement in its Safety, Health, Environmental and QualityManagement by establishing and monitoring annual objectives and targets. The overall siteperformance is measured through a programme of integrated monitoring and assuranceactivities.3.3.3 Waste Management Requirements and the Waste Hierarchy89. Waste Management at RSRL is governed by the following key documents and associatedspecific requirements:90. MAN 0024 - Waste Management Process Manual. This manual sets out the overallQuality Programme for the control, storage, management and disposal of radioactive andnon-radioactive waste, including interfaces with other RSRL processes and references torelevant procedural and other supporting management system documentation.91. PRC 0155 - Management of Solid Radioactive Waste (Including Exempt).Consignments of solid radioactive wastes from RSRL sites need to comply with legal andregulatory requirements, in addition to the requirements of any organisations that willreceive the waste. This procedure sets out the specific management arrangements formaintaining control over solid radioactive waste, and ensuring that it is acceptable foronward processing and/or disposal.92. PRC 0159 – Management of Liquid Discharges. Ensures that liquid discharges throughauthorised discharge point comply with the limits and conditions in the relevant site’sEnvironmental Permit and consents under the Water Resources Act 1991 issued from theEnvironmental Agency and the local water company and are acceptable for discharge towater courses near RSRL sites or disposal to other facilities. Unauthorised discharge ofliquids to the RSRL drainage systems e.g. via a manhole, is not permitted.93. PRC 0191 – Management of Letters of Compliance, Periodic Review of ILW Packagesand Radioactive Waste Management Cases. Ensures that through the LoC processconsistent standards are applied to the conditioning and packaging of ILW and that periodicreviews are carried out to maintain the currency of LoCs for ILW which as been completelyconditioned. Describes how RSRL produces Radioactive Waste Management Cases.94. PRC 0192 – Waste Strategy Management. Ensures that data used in the production ofstrategic technical documents underpinning the LTP is accurate, consistent, regularlyreviewed and updated as necessary.95. PRC 0193 – Management of Radioactive Airborne Discharges. Ensures that discharges,through Authorised Gaseous Discharge Outlets, comply with the limits and conditions in therelevant environmental site permit. This procedure applies to all radioactive airbornedischarges generated and discharged by or on behalf of RSRL from a number of RSRLfacilities/buildings to the environment through the Authorised Gaseous Discharge Outlets asspecified in the site Environmental Permits. The radioactive airborne discharges mayinclude radioactive gases such as tritium and radon, as well as radioactive dusts.RSRL IWS (Issue 5 – October 2012)29

NOT PROTECTIVELY MARKED96. PRC 0199 – Management of Non-Radioactive Wastes. Ensures that RSRL manages anddisposes of non-radioactive wastes in accordance with UK and European waste legislation.This procedure applies to all non-radioactive controlled wastes (including wastes that areexempt/out of scope of regulation as radioactive substances) including hazardous, nonhazardousand inert wastes.• Generated by or on behalf of RSRL• Managed by RSRL as broker, at the Winfrith site97. These documents require Project Managers/ATO holders to:• Ensure that a project waste management plan consistent with the Integrated WasteStrategy is developed and maintained for the facility or project.• Make arrangements to prevent or otherwise minimise the creation of all wasteswhere possible in accordance with the waste hierarchy, and to avoid theunnecessary accumulation of waste.• Categorise waste appropriately, segregating wastes as necessary.• Ensure that the approach taken to manage current and future waste arisingsrepresents the BAT in accordance with the Integrated Waste Strategy.• Check and maintain the effectiveness of arrangements and equipment required tomanage waste, ensuring that the quantities of waste are minimised via robust andtransparent options studies e.g. BAT and that re-use and recycling opportunities aremaximised where practicable.• Maintain documented arrangements for the management and disposal of all wastesacross the site and for each facility or project, ensuring the recording and retention ofrelevant facility and waste information. These include arrangements andresponsibilities for:o Receipt, transport, processing, storage, consignment, disposal of wastes andmonitoring of transfers/consignmentso Maintenance of waste-service agreementso Sampling, monitoring and measuremento Management and retention of information, records etco Management of interfaces with other facilities and projects and other Sites• The site-specific documented arrangements are used to manage the interfacebetween the waste generating processes and the waste receiver.98. There are separate local procedures at each of the site due to the different authorisationarrangements and management and disposal routes.99. Methods for the minimisation of the volume of waste are in line with BAT requirements andinclude:• Avoiding the production of secondary wastes and spread of contamination• Segregating waste types - some are easier to manage, reuse/recycle or dispose ofthan others• Avoiding mixing wastes that are incompatible• Recycling material that would otherwise be waste• Decontaminating to reuse• Reducing volumes through compaction, minimisation of voidage and size reductionby cropping and baling• Setting targets for waste reduction• Reviewing practices and learning from best practiceRSRL IWS (Issue 5 – October 2012)30

NOT PROTECTIVELY MARKED• Audits of consignors against compliance with requirements3.3.4 Good Practice and Research & Development100. The sharing and use of good practice relating to waste management across wastestreams and projects is achieved via the formal meetings listed under the wastemanagement organisation in Section 3.2. RSRL is also involved in numerous cross-industrycollaboration, information exchange, and sharing of good practice activities although thisinvolvement is limited due to funding constraints. Examples include:• Attendance at national working groups such as the Clearance and ExemptionWorking Group (CEWG), the Nuclear Waste Research Forum (NWRF), the Inter-Industry Group on Contaminated Land (IIGCL), Nuclear Safety Advisory Committee(NuSAC) Research Review Group, High Active Waste Strategy Group, Low LevelWaste Strategy Group, Waste Packagers Liaison Meeting and NDA working groups..• Participation in the collaborative development of a cross-industry web-baseddatabase on waste minimisation.• Attendance at conferences and workshops.• Specific industry collaborations on particular issues. For example, RSRL hasattended both NDA and CoRWM workshops relating to the interim storage ofradioactive waste and RSRL is represented on the Encapsulated Metallic UraniumSteering Group (EMUS) and at the Hydrogen Forum.• RSRL is a member of the CIRIA (Construction Industry Research and InformationAssociation) operated by SD:SPUR and SAFEGROUNDS Learning Networks fordeveloping and disseminating good practice on the sustainable management ofmaterials and decommissioning wastes arising from nuclear sites and guidance onthe management of radioactively and chemically contaminated land on nuclear anddefence sites in the UK.• The Low Level Waste National Waste Programme presents all activities identified inthe Joint Low Level Waste Management Plan with the aim of further implementingnational strategy. Monthly meetings are held with all NDA sites to track progressagainst activities and there is a quarterly Delivery Overview Group for considerationof more strategic issues.101. Research and Development (R&D) requirements are currently managed through theRSRL Technical Baseline & Underpinning Research & Development (TBuRD) documentand on a project-by-project basis. R&D needs and opportunities are assessed inaccordance with the requirements of the RSRL project management system and RSRL’sSanction and Validation process as appropriate.. The aim of the TBuRD is to providetransparency of the technologies that underpin the operation and/or decommissioning ofRSRL’s facilities. The TBuRD demonstrates that appropriate R&D activities have beenidentified and are being progressed in order to underpin the plan. Technology needs arealso discussed at the RSRL Waste Strategy Group.102. The management of R&D requirements relating to the packaging and conditioning ofILW is coordinated through the RSRL Waste Strategy section with the support of the supplychain. Contractors such as Babcock’s Science and Technical Group (STG) liaise withprojects on specific requirements and carry out a valuable role in ensuring that commonissues across RSRL and NDA sites relating to ILW packaging are identified and shared.There is a small laboratory at Harwell for small scale trials relating to cementation of wastes- carrying out work for RSRL and other sites.RSRL IWS (Issue 5 – October 2012)31

NOT PROTECTIVELY MARKED103. Technical representatives from RSRL attend the Nuclear Waste Research Forum(NWRF), a forum that discusses all aspects of R&D with each NDA site, regulators andNDA, RWMD. One of the main objectives of NWRF is to review the NDA site TBuRDdocuments to identify common R&D requirements.3.3.5 Skills, Records and Interfaces with Other Sites104. RSRL produces a skills strategy for submission to NDA which, as a minimum, covers:key skills required in the short, medium, and long term; identification of skills gaps and linksto the migration of the existing workforce; sensitivities relating to demographic change;recruitment and training strategies; links with training providers; succession planning; andsupply chain strategies for long-term availability of skills. Each skills strategy also includes atechnical competency framework which incorporates key technical areas including wastemanagement. The sites' skills strategies are analysed and developed by the NDA to ensurethe appropriate supporting infrastructure is in place, and that any key issues or skills gapsare identified.105. The management of records and information is documented in a site “RecordsManagement” Procedure, and the waste management performance reporting sections of theprocedures for the management of radioactive waste, non-radioactive waste, liquid andgaseous waste. These are all available on the intranet.106. The interfaces with other sites relating to waste are managed in a variety of ways:• Handshakes are being developed or are in place to dispatch or receive waste fromother NDA sites. The current status of transfer arrangements with other sites aredocumented in the table in Section 4.5.3, ‘Interactions with Other Sites andOrganisations’.• The transfer of LLW to the LLWR is covered by a contract between LLW RepositoryLtd and RSRL. The contract was renewed in April 2012.• Individual agreements are in place with a variety of waste brokers, waste carriersand waste management contractors for the purposes of reuse, recycling or disposalof a variety of non-radioactive waste types from RSRL sites. These include metalscrap yards, incineration, inert landfill, non-hazardous landfill and hazardous landfill.RSRL IWS (Issue 5 – October 2012)32

NOT PROTECTIVELY MARKED4 INTEGRATED WASTE MANAGEMENT STRATEGY107. The formulation of the RSRL IWS is based on a comprehensive and transparentdecision making process. In support of the IWS, site waste BPEO studies have beenproduced. A site waste BPEO study covers all the radioactive and non-radioactive, solid,liquid and gaseous wastes currently identified as being in existence or due to arise on theHarwell and Winfrith sites. The results of the site waste BPEO studies have beenincorporated into the IWS. Recently the use of BAT has replaced BPEO studies indeveloping and implementing the waste management strategy.108. Prior to generating waste associated with a new project, the relevant ATO Holder,Project Manager or other Senior Manager (hereafter referred to as the senior manager)prepares a written strategy for characterising the waste and managing it up to the pointwhere it passes out of the consignor's custody.The written strategy typically comprises:• A Best Available Techniques (BAT) Assessment of the methods used to processthe waste for long term storage and/or disposal; and• A Waste Conformance Document (WCD) which justifies the techniques used tocharacterise the waste.109. BAT Assessments are approved by the Environment Manager or deputies. WCDs areapproved by the Waste Policy and Compliance Manager or assistants.4.1 Methodology for Strategic Option Studies110. RSRL undertakes a variety of strategic options studies as necessary to develop andimplement the waste management strategy. These have historically comprised BPEOstudies used for the management of wastes, strategic option studies used fordecommissioning projects, and the use of Best Practicable Means (BPM) and Best AvailableTechniques (BAT) methodologies to minimise the production of waste when implementing apreferred option. Following the implementation of the Environmental Permitting Regulationsin 2010, BAT methodologies will be used in place of studies where previously BPEO or BPMmethodology would have been employed, and associated procedures will be reviewed andreissued as appropriate.111. The use of BAT replaces “best practicable means” (BPM) and “best practicableenvironmental option “(BPEO), and is expected to deliver the equivalent level ofenvironmental protection as achieved previously by the use of BPM and BPEO.112. RSRL has recently undertaken high-level strategic BAT reviews for metallic LLW,Winfrith LA-LLW / VLLW and “soft-solid” LLW (formerly this was referred to as “combustibleLLW” however as there are a number of treatment options available for this type ofsecondary waste the term “combustible” LLW is no longer appropriate). These reviewsincluded reassessment of the underlying assumptions and decisions taken at the time of theoriginal BPEO studies. A representative from LLWR Ltd attended each of the reviews.RSRL IWS (Issue 5 – October 2012)33

NOT PROTECTIVELY MARKED113. The term BAT means the latest stage of development (state of the art) of processes, offacilities or of methods of operation which indicate the practical suitability of a particularmeasure for limiting discharges, emissions and waste. In determining whether a set ofprocesses, facilities and methods of operation constitute the best available techniques ingeneral or individual cases, special consideration shall be given to:a) comparable processes, facilities or methods of operation which have recently beensuccessfully tried out;b) technological advances and changes in scientific knowledge and understanding;c) the economic feasibility of such techniques;d) time limits for installation in both new and existing plants;e) the nature and volume of the discharges and emissions concerned.114. The Best Available Technique for a particular process will change with time in the light oftechnological advances, economic and social factors, as well as changes in scientificknowledge and understanding.4.1.1 Option Studies115. RSRL has a procedure for carrying out option studies for the assessment of wastemanagement options against a range of attributes and criteria looking at long and short termimpacts of each option. Preparatory work includes identifying the attributes, constraints, andrisks for the waste stream, and gathering sufficient information to ensure that realisticoptions for its management are identified. Information gathered to identify available optionsincludes current best practice techniques which have been applied elsewhere, new or noveltechniques which have been developed, and any “blue skies” research ideas that may berelevant.116. The procedure for option studies provides a minimum list of attributes to ensure that,regardless of waste type, there is consistency in the consideration of relevant attributes.Attributes include legislative requirements, radiological safety, waste volume andminimisation, technical feasibility, operational constraints, resource requirements,timescales, and cost. However, the procedure does not preclude the use of additionalattributes that may be applicable to a particular study. Workshops are used to analyse theavailable options against each attribute, which is weighted to reflect its importance to thegroup of stakeholders involved. Each attribute for each option is scored, and when theseare totalled the option with the least environmental impact is identified for that particularwaste stream. Sensitivity analysis of the results are undertaken to ensure that one or moreattributes are not disproportionately affecting the result.117. Each site has a preferred strategic options study which covers all the waste being storedor expected to arise during decommissioning. This allows interrelationships betweendifferent waste streams to be recognised so that a consistent strategy for similar wastes canbe developed. Specific studies are also carried out as required.4.1.2 Decommissioning Strategy and Studies118. Decommissioning Strategy documents for both Harwell and Winfrith were produced in2011 and have recently been updated to reflect changes approved by NDA as part of theRSRL IWS (Issue 5 – October 2012)34

NOT PROTECTIVELY MARKEDRSRL Optimisation Programme. The overall strategy and the order in which facilities aredecommissioned are influenced by:• The need to keep the site safe, to prevent environmental harm and to complywith statutory requirements (including site licence conditions)• Programme logic• Hazards and the rate at which the hazard can be reduced• Cost of decommissioning facilities• Cost of maintaining facilities (asset management)• Infrastructure cost savings• Available funding• Site end state119. The decommissioning strategy is also influenced by factors such as technical feasibility(Technology Readiness Level), the potential reuse of the sites and stakeholders.120. Decommissioning strategies are developed for redundant facilities through a series ofstudies at varying levels of detail in which the estimates of cost and timescales areprogressively refined. For Harwell and Winfrith an initial decommissioning study has beenundertaken for every facility on site and a more detailed option study undertaken for each ofthe major facilities. In the run-up to actual decommissioning a number of such studies willbe commissioned. These studies scope what will be involved in decommissioning aparticular facility and will now include a Best Available Techniques (BAT) assessmentincluding investigation of dependencies on other facilities and provide an estimate of therequired timescale, resources, costs, and volumes of waste arisings.121. RSRL, using reach-back to its Parent Body Organisation Babcock Ltd, has developedunderpinned programme level business cases outlining options for optimising the RSRLdecommissioning programme. One of the key aspects of the business case is the ability toconsolidate interim storage of ILW disposal packages, pending disposal to the GDF. Withan existing requirement to build a new ILW store at Harwell the opportunity to extend thescope of this store to include Winfrith ILW has been implemented. It was also proposed thatRobust Concrete Boxes (formerly known as WAGR boxes) be used in preference to the 2mor 3m 3 boxes and this change is also captured in this version of the IWS and othersupporting documents.4.2 Site Prioritisation Logic122. The RSRL objectives are to maintain high standards of safety, security andenvironmental performance whilst eliminating the nuclear liabilities at the lowest lifetimecosts. After essential spend to ensure safety and compliance with environmental andsecurity requirements, available funds will be used for projects taking account of theoutcome of the NDA prioritisation procedure. This scheme prioritises according to:• The rate at which the “hazard potential” from the radioactive material can be reducedover time• The ongoing safety of a building or facility and the uncertainty about the materialsbeing stored, and how these will change over time• The ongoing impact a facility has on the environment• The costs involved, including any change in the ongoing cost of running andmaintaining a facility.RSRL IWS (Issue 5 – October 2012)35

NOT PROTECTIVELY MARKEDThe procedure also takes into account the requirements of the regulators and the viewsof local stakeholders.123. At RSRL sites the major priorities are management of waste streams anddecommissioning of facilities with the higher Safety and Environmental Detriment (SED)Scores. SED scores are calculated using a number of factors and represent both thecurrent ongoing environmental detriment and the potential future hazard from continuedcurrent storage. Facilities with the highest SED scores are shown in the Table below.Site and FacilitySED ScoreHarwellSolid Waste Complex 2.78 x 10 19Radiochemical Building 1.80 x 10 14Liquid Effluent Treatment Plant 9.41 x 10 12WSA 1.82 x 10 12Balance of Site Structures 7.81 x 10 10Active Handling Building 5.4 x 10 9BEPO 3.28 x 10 7MTRs 4.04 x 10 4WinfrithSGHWR 3.91 x 10 11Concrete Lined Drums 2.36 x 10 7Dragon 1.42 x 10 7Minor Facilities 1.41 x 10 7124. The calculations for the NDA Prioritisation Procedure and Hazard Baseline andReduction programme (as described in EGPR02 and EGG06) depend on various metricsassigned to waste streams and buildings. These metrics contain an element of subjectivity,and also may be influenced by ongoing guidance and clarification of the procedures, andtherefore will be subject to regular review.RSRL IWS (Issue 5 – October 2012)36

NOT PROTECTIVELY MARKED4.3 Waste Management Constraints and Dependencies4.3.1 Regulatory Constraints and Dependencies125. The external policy and regulatory framework is complex with regulations / legislationcovering radioactive waste, liabilities management, nuclear facility decommissioning,radioactive discharges, general waste strategies, sustainable development, health andsafety, and security. The main regulatory principles and related drivers and constraintswhich affect RSRL waste management strategy are given in Annex 3 listed under:• Legislative framework• EPR 2010 Permits (formerly RSA authorisations)• Site Licence conditions• EURATOM Treaty requirements• Requirements of the Office for Nuclear Regulation (ONR)• OSPAR Convention4.3.2 Financial Constraints and Dependencies126. Since the last submission of the IWS, the closure programme for the Winfrith site hasbeen optimised. With the NDA's approval, the RSRL Lifetime Plan has been changed andnow takes account of the optimised closure programme and its impact on the closureprogramme for the Harwell site. The revised Lifetime Plan presents a more aggressivedecommissioning programme on the Winfrith site eliminating the need for long term careand maintenance while continuing to deal with the high hazards on the Harwell site, i.e.processing the historic ILW for long term storage and transferring the Nuclear Materials tothe Sellafield site. Also, the Lifetime Plan is consistent with the planning guidance issued bythe NDA for future years (£65M FY 13/14, £70M FY 14/15, £75M FY 15/16 and thereafter).4.3.3 Timing Constraints and Dependencies127. A suitable store is required to be built at Harwell for decommissioning ILW from bothWinfrith and Harwell sites by 2017128. RSRL has several wastes which contain Nuclear Materials (NM) that have arisen as aresult of the research and development programmes carried out on both RSRL’s Harwelland Winfrith sites in support of the UK civil nuclear power programme. These wastes arecurrently stored on RSRL’s Harwell site. An agreement has been reached to transfer thisNM to Sellafield for onward processing and long-term storage. The timing of this will dependon the successful implementation of a 3-phase project (mobilisation of packages andfacilities; shipment of materials off-site; and meeting ONR (CNS) requirements todowngrade the security level at Harwell).129. At Winfrith radiological surveys and decommissioning of a significant number ofbuildings at the eastern end of the site has already been completed and areas at this end ofthe site have been de-licensed. There is a need to transfer all Winfrith ILW to Harwell forlong-term storage by 2022.130. The RSRL waste strategy is dependent on the timing of the GDF. This is currentlyassumed to be available in 2040. Significant cost savings can be made if this facility isavailable early as it would negate or reduce the requirement for long-term storage of ILW onthe Harwell site.RSRL IWS (Issue 5 – October 2012)37

NOT PROTECTIVELY MARKED4.3.4 Technical Constraints and Dependencies131. The key technical constraints involve the repackaging of ILW into final disposalpackages in order to make it passively safe. The strategy is to immobilise the ILW instandard drums or boxes and the implementation of this strategy is dependent on the sitesubmitting and RWMD approving Letters of Compliance (LoC) for each waste stream.Since there is no disposal route for ILW, the current strategy is to store ILW on-site untilsuch time as a national ILW disposal solution is established.4.3.5 Constraints and Dependencies132. The RSRL waste strategy depends on the transport by road of radioactive and nonradioactivewaste. Most transfers are relatively straightforward. However the transfer ofRHILW packaged in 500 litre drums depends on a new Standard Waste Transport Container(SWTC) being available. The SWTC is currently being developed by RWMD. The transferof ILW from Winfrith to Harwell relies on the RCB being re-approved as an IP-2 packageand the assumption that all Winfrith ILW is suitable for this type of container.133. At Winfrith there is potential to bring the existing rail head on the site in to use tominimise potential disturbance to the local communities from road transportation of ILW.4.3.6 Key Site Specific Constraints and Dependencies134. The RSRL waste strategy is dependent on the establishment of a disposal route for ILWto a national Geological Disposal Facility. It also depends on the commissioning of a newILW store on the Harwell site for the long-term storage of both Harwell and Winfrith ILWwhilst awaiting the opening of the GDF.135. RSRL has worked with the private sector to establish a new off-site route for the disposalof LA-LLW and HV-VLLW to landfill. This route is now being successfully utilised by theHarwell site and its continued availability is a key issue for the organisation.136. Previously limited volumes of HV-VLLW from the Winfrith site have been disposed of toa local authorised landfill. However, due to the restriction of annual limits associated withthis route, the Winfrith site is also looking to utilise the newly established route that has beensuccessfully used for Harwell waste. A forward programme has been prepared with a viewto undertaking the first shipment of this waste from Winfrith by January 2013. Whilst RSRLalready has an EA permit which allows disposal of HV-VLLW (material with an activity of4Bq/g) to the landfill. Anapplication for a revision to the existing permit has been drafted and is due to be submittedin the early part of 2013.RSRL IWS (Issue 5 – October 2012)38

NOT PROTECTIVELY MARKED4.4 Site End Points and Contaminated Land / Groundwater4.4.1 HarwellHarwell End State137. The current assumption for the proposed end point for the site is for the nuclear licensedsite to be de-licensed and the NDA designation removed. However it is expected that therewill be chemical licences from the Environment Agency (EA) in place for the WesternStorage Area. The detailed physical end state includes clean buildings, structures, roads,drains and grouted abandoned drains that will remain, and is described in the Site End StateDocument.138. The site is planned to be developed as part of a world-class science and technologycampus known as Harwell Oxford Campus, in line with recent government policy decisions.At present the end point for the land occupied by the remaining nuclear facilities involves delicensing.139. The strategy for ILW plays an important role in the site end point. The current LTPbaseline strategy for legacy RHILW (excluding Dragon waste) and decommissioning CHILWis storage on-site until a Geological Disposal Facility (GDF) is available (assumed to be2040). The strategy for legacy CHILW and Dragon Waste is to transfer it to Sellafield foronward processing and disposal as part of the Nuclear Materials Transfer project. Thesestrategies have a significant impact on the site end point in relation to both timing and itsphysical state. Legacy ILW will be in a passively safe state in storage on the Harwell site by2023. The final end state when all ILW has been transferred to the GDF and the whole sitehas been de-licensed will now be achieved in 2050.140. The current approach to de-licensing is to divide the eastern area of the site into zonesand to de-licence each zone on a case by case basis. Five hectares of land was delicensedin 1992, followed by a pilot area of 7 hectares in 2006. In January 2012 the ONR approvedthe delicensing of 6 hectares of land known as the North Gate and Building 146/149 Areas.Future areas for de-licensing and land development will be established as land becomesavailable.141. When the site end point is achieved there will be a waste management licence for theWestern Storage Area (WSA) closed landfill. Even though the landfill has been excavatedand emptied, it is unlikely that this waste licence will be able to be surrendered because landand groundwater contamination will remain. The WSA Groundwater Containment Plant isalso licensed but it is assumed that EA will agree to the termination of its operation by 2025.142. An external stakeholder consultation on the Harwell site end state was carried out by theLocal Stakeholder Group (LSG) and made a recommendation to NDA in 2007. Therecommendation stated that “The Harwell LSG recommends that the End State for Harwellshould be 100% de-licensed”. This recommendation is not inconsistent with the currentstrategy however the date originally proposed by the LSG of 2020 is not compatible with thetimescales expected for decommissioning the Harwell site.143. In addition, the transfer of ILW to the GDF is beyond RSRL direct control, and delays inthe provision of solutions to these issues may prevent the site being de-licensed by 2050.Currently ILW is scheduled to be transferred between 2040 and 2047.RSRL IWS (Issue 5 – October 2012)39

NOT PROTECTIVELY MARKED4.4.1.1 Harwell Contaminated Land and Groundwater144. The land and associated groundwater on the Harwell site have been surveyed over anumber of years in order to determine the extent and concentration of contaminated landand groundwater. Results of these surveys are documented and processed using aGeographical Information System (GIS) based records management system developed toenable the systematic collection, interpretation and assessment of associated data. Thesystem is known as IMAGES - Information Management and Geographical EvaluationSystem.145. Operations on the site have resulted in contaminated land liabilities associated with thebuildings, services and open areas. These liabilities continue to be surveyed andremediated to a “no danger from ionising radiation” standard, in line with good practicechemical standards, and conditions suitable for re-use in accordance with sustainabilityprinciples.146. Radioactive contaminated land associated with individual facilities may be present dueto historic spills involving liquids. This contaminated land will be remediated as part of theindividual facility’s decommissioning and site remediation programme prior to final survey forde-licensing. Radiologically contaminated land that lies between facilities on the Harwellsite is either a legacy associated with a facility already decommissioned and removed or anarea where material has been moved from one part of the site to another, such as theMeashill Trenches.147. The main non-radioactive chemical contamination of land is at the Western Storage Area(WSA) which was used for the licensed sorting, treatment and landfill burial of chemicalwastes from Harwell and other laboratories in the period 1965-1996. The disposal ofhazardous chemical wastes into shallow unlined chalk pits resulted in a serious aquiferpollution incident stretching 8 km offsite. The chemical pits were remediated in 2005 andthe resultant chemically contaminated wastes have been removed for off-site disposal atsuitably licensed waste disposal facilities.148. The chemically contaminated groundwater from the WSA has been subject to amonitoring programme since 1989 and pump/treat groundwater containment since 1993.During 2011/12 the Unsaturated Zone Remediation Project completed its work to removeover 3000kg of pollutants from the area. The strategy going forward is to:• continue to pump and treat groundwater using the WSA Groundwater ContainmentPlant until 2025• continue a monitoring programme from 2025 to 2050• continue a programme of “monitored natural attenuation” until the entire plumeimproves to better than drinking water standards149. It is possible that a liability will remain for groundwater from the WSA at the end of thesite restoration programme.4.4.2 WinfrithWinfrith End State150. The Winfrith site will be closed at the Interim End State then passively managed byapplying land use restrictions whilst residual radioactivity decays. After a period of time(envisaged to be decades), the site will reach a condition when it can be de-licensed thende-designated at which pint the land use restrictions will no longer be required.RSRL IWS (Issue 5 – October 2012)40

NOT PROTECTIVELY MARKED151. As the buildings are cleared, the areas of ground exposed through demolition and theareas of land between buildings will be surveyed for any residual radioactivity. The requiredremediation for each area of land, e.g. excavation of below ground structures, will be subjectto stakeholder agreement and regulator approval.152. Remediation activities will include:• Identifying the contamination within the soil and groundwater.• Assessing whether the identified contamination requires remediation.• Identifying the BAT for remediation of soils and groundwater.• Removal of contaminated soil and groundwater for treatment and re-use or disposal.Winfrith Contaminated Land and Groundwater153. Current estimates indicate that about 500m 3 radioactive waste will be generated fromcontaminated land remediation activities. This will impact on the site IWS as it may increasethe volumes to be sent to the LLWR depending on whether or not soil cleaning is identifiedas BPEO. Use of waste materials to back-fill voids is being discussed with the EnvironmentAgency. The baseline strategy assumes that building rubble can be used to back-fill voidsduring demolition and soil can be used for landscaping with the appropriate permits.Winfrith has already used 4,000 - 5,000 tonnes of non-radioactive/exempt subsoil andtopsoil on site.154. The Environment Agency requires RSRL to review and rationalise its existinggroundwater regimes to ensure that the groundwater monitoring programme effectivelymonitors groundwater whilst decommissioning operations progress. The regime mustreflect current knowledge and understanding and provide suitable information to ensureRSRL does not affect groundwater during the Site Closure Programme. The regime chosenwill incorporate existing boreholes and may require additional boreholes to support specificbuilding, decommissioning, and demolition, or if land contamination is identified. There hasalso been found to be zinc contaminating the groundwater which is discussed further inSection 7.3.4.1155. Historical information indicates that tritium has leaked to ground in the vicinity ofSGHWR and the External Active Sludge Tanks (EAST). The maximum tritium activity ingroundwater was measured on the Winfrith site during February to April 2003, and wasfound to be below European drinking water levels standards; activity levels have sincedecreased significantly. The level is currently less than 10Bq/g and it is proposed to leavethis in-situ underneath SGHWR to allow this tritium to decay naturally and migrate with thenormal groundwater flows. Verbal agreement has been obtained from EA to this proposal.156. When the land and groundwater condition meets the HSE de-licensing criteria, the sitecan be de-licensed.4.5 Assumptions, Exclusions, Risks and Opportunities157. Assumptions and exclusions are addressed in accordance with NDA requirements inPCP-09 for Cost Estimating and the management of risk is carried out in accordance withNDA requirements in PCP-10 for Risk Management.4.5.1 Key Assumptions158. The RSRL IWS is based on a number of key assumptions relating to waste which applyto the current LTP baseline programme. The major assumptions are provided below.RSRL IWS (Issue 5 – October 2012)41

NOT PROTECTIVELY MARKEDNDA STRATEGIC AND TECHNICAL ASSUMPTIONSAssumptionJustificationExisting waste categories (HLW, ILW, LLW, LA- NDA assumptionLLW, HV-VLLW, Hazardous, Exempt and Non-Hazardous) are the only ones valid for makingwaste management decisions for solid waste.LLWR will remain available on a continuous basis. NDA assumptionContingency plans to ensure that this is the case willbe developed as part of the LLWR Lifetime Plan.The Geological Disposal Facility is available from NDA assumption2040 onwards.Radioactive Discharges will be consistent with the NDA assumptionUK Radioactive Discharges Strategy. This will meetOSPAR Convention requirements.Plans are consistent with the requirements of the NDA assumptionWater Framework Directive and relevant RiverBasin Management Plans.AssumptionThe ILW packages in their passively safe condition willbe acceptable for disposal in the GDF.RSRL AssumptionsJustificationFinal package configurations have been or will beapproved by NDA RWMD before use.Sufficient Low Level Waste (LLW) disposal routes areavailable to support waste processing anddecommissioning activities.Radioactive material processing and decommissioningwill occur as soon as practicable within the constraintsof the current NDA annual site funding limit (ASFL)profile.Disposal routes will be available for contaminated oilsand solvents and for hazardous and non-hazardouswaste with their acceptance criteria taking intoaccount the requirement for OSPAR (Oslo ParisConvention).No significant work, beyond the work required to meetregulatory requirements, is needed to remove the NDAdesignation of the sites.The extent of contaminated land on both sites is basedon historic records and characterisation data.Radioactive material which is being stored on behalfof or by tenants or other organisations will be removedfrom the Harwell and Winfrith sites by the owner in atimescale that does not impact thedecommissioning programme.There will not be any major changes to modernstandards that apply to regulatory requirements.The NDA is responsible for providing adequate LLWroutes to support its programme.The NDA sets the ASFL profile for each site basedon the total available funding and nationalpriorities.RSRL is not aware of any proposals to terminatethese disposal routes.The NDA have confirmed that no significant work isrequired to remove the NDA designation of the sitesafter achievement of the necessary regulatoryapprovals.Historic records and characterisation are sufficient toestimate the cost of remediation when combined withappropriate risk and contingency assumptions.The waste owners hold the obligation for their wasteremoval and disposal. Agreements are in placedocumenting the owners' obligations.RSRL is not aware of any planned significantchanges to modern standards.RSRL IWS (Issue 5 – October 2012)42

NOT PROTECTIVELY MARKEDAssumptionThe EA will consent to termination of the WSAGroundwater Containment Plant operations in 2025.The end state of the property is acceptable for itsincorporation into the Harwell Oxford Campus. This isdefined as termination of the ONR licence withappropriate EA permits for the Western Storage AreaThe Harwell discharge pipeline will be removed wherepracticable although the sections that are in-accessiblewill be capped and grouted.Low Enriched Uranium (LEU), Dragon waste (HEU)cans, Concrete Lined Drums (CLDs) and certainCHILW drums will be shipped off-site for onwardprocessing, long-term storage and disposal as plannedat Sellafield site.The remaining Intermediate Level Waste (ILW) e.g.excluding the ILW that is planned to be shipped offsite,will be stored on-site, in passively safe states, inappropriately engineered storage facilities, until it isshipped to the Geological Disposal Facility (GDF)starting in 2040Security services will be provided at the current leveluntil material of concern is removed from the Harwellsite.The site will transition to a secure storage mode ofoperations, at the Solid Waste Management Facilityafter all decommissioning is completed.AssumptionAll Intermediate Level Waste (ILW) will be transferredto RSRL Harwell site, in passively safe states, whereit will be stored in appropriately engineered storagefacilities, until it is shipped to the Geological DisposalFacility starting in 2040Agreement can be reached with the Regulators that itwill only be necessary to excavate structures to aminimum depth of 1 metre below ground level, wherestructures remaining in the ground can bedemonstrated to comply with the interim end statecriteriaDecommissioning Intermediate Level Waste (ILW)will be packaged, stored, and disposed of in RobustConcrete Boxes.The Ministry of Defence (MoD) will allow access tothe Lulworth firing range to decontaminate the SeaDischarge Pipeline.Decommissioning of the Electrical Substations is notrequired.HARWELLJustificationExtrapolation of current groundwater data indicatesthat termination of these activities should be achievedby the dates stated. The EA have been consultedand have not objected to this conclusion, subject toverification through actual performance.The end state for the site is consistent with theNDA strategyIt is uncertain that, without characterisation andregulatory consultation, approvals can be received todecontaminate, grout, and leave the pipeline inplace.Handshake is in place to transfer nuclear materials tothe Sellafield site. Regulators have bought into thisstrategy.GDF availability and the frequency for ILW transfer willbe determined as a part of a national programme.Reduction to the threat level is not expected and isexpected to remain comparable over the duration ofthe programme.ILW must be stored securely onsite until it is shippedto the GDF.WINFRITHJustificationThis philosophy is consistent with the NDAstrategy for higher activity waste storage review.This philosophy has already been agreed with theEnvironment Agency and ONR for some parts ofthe site where excavation and land restorationwork has been completed.The Robust Concrete Box is an accepted ILWdisposal package, and is suitable for loading andinterim storage.The MoD is aware that pipeline decommissioningis required and has not objected to the workassuming the establishment of appropriatearrangements.The electrical Substations are leased to Scottish &Southern Electric for 99 years.RSRL IWS (Issue 5 – October 2012)43

NOT PROTECTIVELY MARKEDAssumptionMaterial from the demolition of major buildings,including SGHWR and Dragon reactor containments,will be used to back-fill the below ground voidscreated by the demolition of the structures.4.5.2 Risks and OpportunitiesWINFRITHJustificationDiscussions with the ONR and EA are ongoingwith the purpose of agreeing the optimum solutionfor the management of this waste.159. Risks are identified by means of a top down (strategic) review and bottom up (project)review to capture events which may impact positively or negatively on the outcome ofobjectives. The Group 1/ Group 2 Exception Process is used to identify those risks that arewithin the defined contract scope and are the responsibility of the SLC to manage, andthose outside the scope of the contract. The risks are assessed using the NDA CombinedProbability Impact Diagram and managed by identification of risk owner and mitigatingactions. Appropriate contingency is generated by modelling discrete risks throughPertmaster, an industry-standard risk analysis software. Risks are reviewed regularly andreported as appropriate.160. All risks to the RSRL programme, including those relating to waste, are captured on thesite risk register which records a description of the risk, its probability, consequence,mitigating actions and magnitude in terms of time and cost. The top level risks andopportunities to the RSRL strategy for waste in the current LTP baseline, together with theconsequences and mitigating actions, are summarised below.ThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateRSRLSufficient waste disposal routes are not available to support thedecommissioning programmes.Project end dates would extend increasing programme costs. Wastedisposal costs would increase for the next best available alternative.Continue to assist the NDA and third parties in maintaining and identifyingnew waste disposal routes.OngoingFailure to obtain planning permission for a Harwell ILW store to takeWinfrith ILW.ILW would remain at Winfrith until an alternative location becameavailable.Continue communications with Oxfordshire County Council planningdepartment. Continue stakeholder engagement. A scoping assessmenthas been communicated at Harwell Stakeholder Group. Emphasise thatcontinuing the decommissioning programme at Harwell will generate thelocal need for the ILW Store.February 2013Significant contamination identified in land areas (open and underbuildings) previously assumed to be unaffected or minimally contaminated.Significant amount of additional funds would be required to remove anddispose of contaminated soils.Continue to review historical records and perform characterisation of siteland areas.Characterisation will be sequenced into the decommissioning plans andexecuted as funds become available.RSRL IWS (Issue 5 – October 2012)44

NOT PROTECTIVELY MARKEDThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateRSRLILW packages in passively safe condition (as currently agreed) are notaccepted in the Geological Disposal FacilityAdditional costs and facilities will be required because ILW packages mustbe repackaged or over-packed prior to shipment to the GDF resulting inextended timescales.Packages produced in agreement with RWMD letter of complianceprocess.OngoingIncreased security costs as a result of increased alert state, subcontractorcosts or physical requirementsIncreased costsLiaise with security representatives (ONR and CNC) to maintainappropriate level of security. Develop the business case to relocatematerial requiring enhanced security to another site.OngoingThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateHarwellFacilities become structurally unsound before the end of the extended careand maintenance periodSignificant amount of additional funds would be required to maintainstructural integrity before decommissioning or early decommissioning isrequired.Perform engineering analyses of the facilities to identify potential issues.Implement maintenance programmes to preserve structural integrity.Prioritise work to allow earlier decommissioning of failing structuresOngoingRSRL loses site knowledge and expertise through staff attrition.Greater reliance on documentation to plan and execute decommissioningactivities resulting in increasing execution costs.Maintain effective knowledge management process.OngoingDelicensing criteria cannot be met without removing residual subsurfacestructuresIncreased costs resulting from additional excavation requirements.Develop robust delicensing case for leaving sub-surface structures inplace. Liaise with regulators to ensure that this approach remainsacceptable within the delicensing criteria.OngoingRSRL IWS (Issue 5 – October 2012)45

NOT PROTECTIVELY MARKEDThreatPossible ImpactMitigationActivitiesKey DecisionDateThreatPossible ImpactMitigationActivitiesKey DecisionDateWinfrithSite interim end state criteria cannot be met without removing residual subsurfacestructures or residual contamination at depth.Increased costs resulting from additional excavation requirements.Liaise with Regulators to develop appropriate interpretation of the siteinterim end state criteria.OngoingRSRL loses site knowledge and expertise through staff attrition before siteinterim end state is achieved.Greater reliance on documentation to plan and execute decommissioningactivities resulting in increasing execution costs.Maintain effective knowledge management process. Consider the use ofincentives to retain key staff.OngoingOpportunityPossible BenefitDelivery ActivitiesKey DecisionDateRSRLEstablish appropriate alternatives for the treatment or disposal of LLW toavoid disposal at LLWRReduction in the volume of LLW disposed of at LLWRContinue discussions with LLWR about alternative routesOngoingOpportunityPossible BenefitDelivery ActivitiesKey DecisionDateOpportunityPossible BenefitDelivery ActivitiesKey DecisionDateHarwellReturn Low Enriched Uranium (LEU) to the civil nuclear fuel cycle ratherthan disposing of it as waste.Reduction in waste disposal costs and increased value from recovereduraniumDevelop alternative route for LEU processingMarch 2013Relocate ILW to an alternative site before disposal in GDF andaccelerate decommissioningReduces ILW storage and care and maintenance costs while allowingaccelerated decommissioningDevelop a final business case for consolidation of ILW with that of otherSite Licence Companies, which will facilitate site closure.OngoingRSRL IWS (Issue 5 – October 2012)46

NOT PROTECTIVELY MARKEDOpportunityPossible BenefitDelivery ActivitiesKey DecisionDateOpportunityPossible BenefitDelivery ActivitiesKey DecisionDateHarwellLeave large portions of the Harwell Discharge Pipeline in place afterdecontaminating and grouting.Reduction in programme costs and potential environmental advantagesfrom not disturbing large sections of land between the site and the RiverThamesEvaluate the Best Available Techniques for the disposal of the HarwellDischarge Pipeline as part of the future decommissioning strategy.March 2013There is an opportunity to make significant savings through review oftechnical solutions at HarwellSignificant reduction in costs, freeing funding for decommissioningReview and recommend the technical solutions for decommissioningmethodology. Prepare a revised baseline once the recommendedoptions are with NDA.March 2013OpportunityPossible BenefitDelivery ActivitiesKey DecisionDateWinfrithSell the Thorium material currently stored on the Winfrith siteCost saving from not having to dispose of the Thorium as wasteContinue discussions with interested partiesJuly 2013RSRL IWS (Issue 5 – October 2012)47

NOT PROTECTIVELY MARKED4.5.3 Interactions with other Sites or OrganisationsDonor /RecipientSiteHarwell toLLWRHarwell toInutec LtdWinfrithHarwell toSellafieldHarwell toLLW LandfillHarwell toNonhazardousWasteLandfillHarwell toHazardousWasteLandfillHarwell toWinfrithWinfrith toHarwellW&NM Category& DescriptionLLWCompactable &non-compactable.LLW & Nonradioactiveoilsand solventsLLWCompactablePlannedDatesOngoingOngoingNuclear Materials 2013-2022LA-LLW (up to200Bq/g) and HV-VLLW (up to4Bq/g except fortritium which is upto 40Bq/g)Non-radioactivenon-hazardouswasteNon-radioactivehazardous wasteLLW metal waste OngoingEncapsulatedILWTransfer Programme StatusContract in place (renewed inApril 2012). Compactable LLW indrums via WAMAC and bulk noncompactableto LLWR fordisposal. Oils and solvents toincinerator.Contract in place between RSRLand Inutec for super compactionprior to disposal in the LLWR.Transfers are fully implemented inthe RSRL approved baseline.They have also been formallyadopted into the Sellafieldbaseline however the detailedscope of work is still underdevelopment.TransferProgrammePositionGreenGreenGreenOngoing Contract in place GreenOngoing Contract in place GreenOngoing Contract in place GreenOngoingThis is a baseline activity.Transfer to Winfrith for treatmentin WACMThis is a baseline activity.Transfer to Harwell for long-termstorageGreenGreenWinfrith toLLWRLLWCompactable &non-compactable.LLW & Nonradioactiveoilsand solventsOngoingContract in place (renewed inApril 2012). Compactable LLW indrums via WAMAC and bulk noncompactableto LLWR fordisposal. Oils and solvents toincinerator.GreenRSRL IWS (Issue 5 – October 2012)48

NOT PROTECTIVELY MARKEDDonor /RecipientSiteWinfrith toLLW LandfillWinfrith toNonhazardousWasteLandfillWinfrith toHazardousWasteLandfillW&NM Category& DescriptionLA-LLW (up to200Bq/g) and HV-VLLW (up to4Bq/g except fortritium which is upto 40Bq/g)Non-radioactivenon-hazardouswasteNon-radioactivehazardous wastePlannedDatesTransfer Programme StatusTransferProgrammePositionOngoing Currently under development AmberOngoing Contract in place GreenOngoing Contract in place GreenKey to status of transfer programme:Green: Agreement in place, where appropriate donor and recipient sites have transfer intheir baselines.Amber: Negotiations at an advanced stage, where appropriate the donor site has thetransfer in its baseline and the recipient site has the transfer as an opportunity.Red: Negotiations have started, where appropriate the donor site has the transfer in itsbaseline but the recipient site does not.161. The waste disposal and authorised transfer routes from the Harwell and Winfrith sitesare tabulated in Annex 2. Contracts and agreements for disposal to hazardous and nonhazardouslandfill sites are generally put in place on a project by project basis. Waste fromoffices is collected for recycling or disposal under a site-wide Facility Services Contract.4.6 Stakeholder Engagement162. RSRL has adopted a strategy of openness as stated in its policy on the RSRL Intranet:• Site stakeholders will be identified and plans put in place to communicate with them• Significant projects and major operational activities will produce stakeholdercommunication plans• Development of stakeholder management skills in staff will be encouraged.163. The objective of RSRL stakeholder communication plans is to ensure that all relevantstakeholders have been provided with balanced, clear, factual and truthful information aboutRSRL and its sites in order to facilitate openness and trust in all our stakeholders.164. As part of RSRL project management framework every project including those relating towaste has a statement of requirements in which there is a section identifying keystakeholders. This enables the project to ensure that the requirements of each stakeholderare addressed.165. For RSRL there are three Stakeholder Groups. The RSRL Regulatory Forum; forHarwell the Local Stakeholder Group (LSG); and the Winfrith Site Stakeholder GroupRSRL IWS (Issue 5 – October 2012)49

NOT PROTECTIVELY MARKED(WSSG). The RSRL Regulatory Forum is attended by representatives of NDA, ONR, EA,local councils and local government.166. The Stakeholder Groups consist of interested parties such as tenants of the Harwell andWinfrith sites, local government representatives and regulators and have an independentChairman. Topics of interest to stakeholders are tabled at these groups and include thereporting of environmental discharges and disposals from the sites. Attendees from thelocal Stakeholder Groups also attend the NDA National Stakeholder Group Meeting.167. The strategy for stakeholder engagement is justified by the achievement of a goodworking relationship with many internal and external stakeholders. Stakeholders range frompeople or groups with a detailed interest or general interest; who are internal or external tothe organisation and who have a large or small influence on the project. Stakeholders withan interest in waste strategy at RSRL sites include:• RSRL staff• Regulators, such as ONR, EA and DECC• NDA• Local government representatives• Tenants on the site• Neighbours of the site• Local Stakeholder Group• Other NDA sites• Third party waste disposal and processing facilities168. Stakeholder engagement on the formulation of the IWS and specific waste issues islargely achieved through the public participation process that forms a major part of theBPEO process, see section 4.1. A site waste BPEO study with consultation of internal andexternal stakeholders has been undertaken at both Harwell and Winfrith. Stakeholders wereinvited to comment on the BPEO process including the technical objectives, constraints,risks, attributes, options, assessments and results. Comments have been reviewed and,where appropriate, fed into the output from the BPEO study. The study covers all theradioactive, non-radioactive, solid, liquid and gaseous wastes currently identified as being inexistence or due to arise on the relevant site. Where some of the waste streams alreadyhave mature strategies currently being implemented or have been the subject of a separateBPEO study, these are simply listed in the site waste BPEO studies, rather than duplicatingwork already completed.169. Since the BPEO study options for processing and storage of NM at Sellafield havebecome more technically feasible. A BAT assessment including several options in additionto those considered in the BPEO study has been carried out to underpin the NM transfersprogramme. A summary of the changes to the preferred option for the NM stream as aresult of the BAT assessment will be shared with local stakeholders.170. Stakeholder engagement on specific waste management issues which do not warrant aBPEO-type study is planned both internally and externally. Internal stakeholders areconsulted through formal strategy and progress meetings and via the RSRL intranet. Whereappropriate, external stakeholders are consulted on particular waste issues, such astransfers off and on site, through the local Stakeholder Groups and the EnvironmentalRegulators Review meeting.171. In order for stakeholder engagement to be effective, targeted and proportionate, it isimportant that stakeholders are not flooded with information and requests for involvementand reaction to waste management issues. Thus prioritisation of the number and level ofRSRL IWS (Issue 5 – October 2012)50

NOT PROTECTIVELY MARKEDstakeholder consultations is important. Detailed studies with full external stakeholderconsultation are used sparingly which is why most waste streams have been covered by thesites’ waste BPEO. Significant waste management issues are raised at regular forums,such as the Local Stakeholder Group, Winfrith Site Stakeholder Group, or weekly NDAmeetings. Day-to-day waste management issues are discussed internally at regularmeetings, such as those mentioned in Section 3.2.172. Waste issues are communicated internally within RSRL and the Harwell and Winfrithsites in a variety of ways including meetings and reports from the relevant people involveddirectly in waste issues. Messages via email or on the RSRL intranet and regular briefingsinform all personnel of general issues relating to waste.173. The strategy for stakeholder engagement relating to waste at the Harwell and Winfrithsites take account of external stakeholder engagement, such as the government outputrelating to Managing Radioactive Waste Safely programme. Stakeholder engagement plansrelating to waste transfers to or from another site are managed in discussion with therecipient or donor site.RSRL IWS (Issue 5 – October 2012)51

NOT PROTECTIVELY MARKED5 OVERVIEW OF SITE WASTE STRATEGY174. The RSRL integrated waste strategy is compliant with the concept of waste minimisationby applying such concepts as the Waste Hierarchy, Best Available Technique (BAT) andBest Practicable Means (BPM). Since the introduction of the Environmental PermittingRegulations in 2010 the BAT process only will be used to ensure compliance with wasteminimisation. Once waste has arisen or when it already exists, the strategy is to segregatethe waste to the lowest hazard or radioactivity category and to make full use of the availabledisposal routes. When this is not possible, such as for ILW, the strategy is to make thewaste passively safe for long term storage.175. The RSRL IWS and other interrelated strategies link together to make up the overallstrategy for safely managing historic wastes currently in stock and future arisings fromdecommissioning from the Harwell and Winfrith sites. Other strategies linked to the IWSwhich support the site strategy include:• Decommissioning Strategy• Land Quality Strategy• Site End State Strategy176. In September 2011, RSRL and in collaboration with the national Low Level WasteRepository (LLWR) issued a joint LLW Management Plan. The plan is a proactivedocument to assist in implementing the UK LLW Strategy. RSRL has made significantprogress in seeking alternatives to direct disposal of waste to LLWR by actively developingroutes for the disposal of LA-LLW and HV-VLLW to off-site landfill. Although RSRL has yetto make use of the metallic waste treatment service offered through the contract with LLWRthis service is recognised as beneficial to decommissioing activities. During 2011, RSRLand LLW conducted a joint review of options for making RSRL’s surface decontaminationservice available to other nuclear operations and concluded that there was already sufficientcapacity to adequately serve the nuclear industry at that time. This position was reviewed inJune 2012 with the same conclusion. There is scope for further alignment of RSRLsactivies with the National Strategy and RSRL continues to work collaboratively with LLWRand other SLCs to develop best practice arrangements in waste management.177. The Environmental Permitting (England and Wales) (Amendment) Regulations 2011were adopted by RSRL with effect from 29 th January 2012. The regulations set out a newsystem for exemption from the radioactive substances regulations. Exemption Orders madeunder the Radioactive Substances Act 1993 were removed, consolidated or otherwise redrafted.This change removed the Substances of Low Activity (SoLA) Exemption Order andthe concept of SoLA was replaced by a series of specific-activity limits for individual radionuclides.As long as waste does not exceed the individual radio-nuclide limits it can bedeemed to be ‘out of scope’ of regulation as a radioactive substance. The 0.4Bq/g forexemption under SoLA is no longer relevant.178. Whilst the adoption of the Environmental Permitting (England and Wales) (Amendment)Regulations 2011 change has been applied within RSRL, a decision has been made tocontinue to refer to this waste as ‘exempt’ rather than ‘out of scope’ in order to avoidconfusion with references to ‘scope’ in the Lifetime Plan.179. RSRL, using reach-back to its Parent Body Organisation Babcock Ltd, has developedunderpinned programme level business cases outlining options for optimising the RSRLdecommissioning programme. One of the key aspects of the business case is the ability toconsolidate interim storage of ILW disposal packages, pending disposal to the GDF. WithRSRL IWS (Issue 5 – October 2012)52

NOT PROTECTIVELY MARKEDan existing requirement to build a new ILW store at Harwell the opportunity to extend thescope of this store to include Winfrith ILW has been implemented. It was also proposed thatRobust Concrete Boxes (formerly known as WAGR boxes) be used in preference to the 2mor 3m 3 boxes and this change is also captured in this version of the IWS and othersupporting documents.5.1 Harwell180. The Harwell site strategy is to package all ILW into final disposal packages anddecommission all redundant facilities, except for the Shielded Vault Store, the WasteEncapsulation Plant, the new Harwell ILW Store and some facilities in the Solid WasteComplex, by 2032. Much of the site will have been de-licensed and other areas will beready to be de-licensed by the ONR. LA-LLW and HV-VLLW suitable for landfill will havebeen transferred to an off-site disposal facility and the WSA Groundwater Containment Plantoperations will have ceased.181. By the Final End State in 2050, all the ILW will have been transferred to the GDF eitherdirectly or, in the case of the Nuclear Material Transfer project, via Sellafield. All LLW will betransferred to off-site disposal facilities by 2049. The stores and remaining facilities in theSolid Waste Complex will have been decommissioned, all redundant buildings demolishedand all the remaining land remediated and de-licensed.182. The Final End State will be achieved by implementing the Harwell DecommissioningStrategy which features the key milestones listed in section 2.1 and the Integrated WasteStrategy which features the key milestones listed below:YearKey Milestone2014 Waste Encapsulation Plant (WEP) operationalNew Harwell ILW Store for Winfrith ILW and2017 Harwell reactor and RCF decommissioning ILWavailable2023 Passive safety of wastes2032 MTRs decommissioned and wastes packaged2040 Transfer of packaged ILW to the GDF commences2050 Final End State (all land delicensed)183. The inventory of radioactive and non-radioactive waste already in stock or due to ariseon the Harwell site is given in Annex 1. Following the sharing of lessons learned from theMagnox SMART Inventory exercise with respect to underpinning of waste volumes, RSRLhas undertaken a similar exercise for the Dragon reactor at Winfrith. This exercise will berolled out across the rest of Winfrith and RSRL over the coming year.184.185. A summary of Harwell waste arisings for the main waste categories with current storageand disposal routes is given below and addressed in detail in Section 6.RSRL IWS (Issue 5 – October 2012)53

NOT PROTECTIVELY MARKEDFuture storage / disposal route SectionRadioactive Waste Type Volumein m 3Raw RHILW in stock 121.3 Retrieval from storage tubes; processing 6.1.2.1(in tube stores)and packaging into 500-litre drums. Groutin WEP; store on-site long-term; disposal inGDFRHILW in stock76 Retrieval from vault store; processing and 6.1.2.1(in temporary storage in500-litre drums)re-packaging into 500-litre drums. Grout inWEP; store on-site long-term; disposal inGDFDragon Waste 3.4 Transfer to Sellafield Ltd for processing and 6.1.2.2final disposal in GDFRHILW in 500-litre drums 169.5 Grout in WEP; store on-site long-term; 6.1.2.1disposal in GDFILW future arisings fromdecommissioning of AHF,RCF and reactors506 Package decommissioning ILW into 500-litre drums, RCBs or 3m 3 boxes; groutdrums; long-term storage on-site; grout6.1.2.1and6.1.2.3CHILW future arisings fromdecommissioning of SolidWaste ComplexLarge NDS sources (toolarge or heavy for 500-litredrums)boxes; disposal in GDF25 Package decommissioning CHILW into200-litre drums. Transfer to Sellafield Ltdfor processing and final disposal in GDF.1.8 Package sources into 3m 3 boxes; grout incurrent facility. Store on-site long-term;disposal in GDF.Encapsulated ILW Liquors 20.5 Store in 500 litre drums on-site long-term;disposal in GDFILW Concrete Lined Drums 1,061 Transfer to Sellafield Ltd for processing andfinal disposal in GDFNuclear material suitablefor recovery18.1 LEU - Transfer to Sellafield Ltd forprocessing and final disposal in GDFNU/DU – Store long-term on site;packaging into 500 litre drums; groutdrums; disposal in GDFRaw CHILW in 200 litredrums plus arisings782 Transfer to Sellafield Ltd for processing andfinal disposal in GDFEncapsulated ILW Sludges 3.38 Store in 500 litre drums on-site long-term;disposal in GDFLLW in stock across site 1,651 Package in ISO disposal container andand operational arisingsdisposal in LLW repositoryLLW future arisings from 8,464 Package in ISO disposal container anddecommissioningdisposal in LLW repositoryLLW (solvents, oils and 1 Transfer organic waste, oils or solvents fororganic wastes) stocks anddisposal by incinerationarisingsLLW 14 arisings suitable forlandfill6.1.2.26.1.2.16.1.2.16.1.2.26.1.2.26.1.2.26.1.2.16.1.36.1.36.1.324,148 Disposal at off-site LLW landfill facility 6.1.314 Formerly known as High Volume Low Activity (HVLA) wasteRSRL IWS (Issue 5 – October 2012)54

NOT PROTECTIVELY MARKEDNon-Radioactive Waste Type Disposal route SectionHazardous waste arisings Recycle, incineration or collection and disposal to 6.3.1hazardous landfill via licensed waste contractorNon-hazardous arisings Recycle scrap metal and paper off-site6.3.2Disposal to off-site landfillInert wasteReuse crushed concrete/rubble as infillReuse clean soil for landscapingDisposal of excess to off-site landfill6.3.3Discharges Discharge Route SectionRadioactive liquidRadioactive gasNon-radioactiveliquidNon-radioactivegasTreatable active effluent (with levels of activity sufficient fordecontamination to be viable) is decontaminated beforedischarge to the River Thames via the Sutton Courtenaydischarge pipeline or the public foul sewer. Non-treatableactive effluent (decontamination is not viable) such as tradewaste is sampled and monitored before discharge to the RiverThames or the public foul sewer. Oils and solvents aredisposed of by incineration.Gaseous radioactive emissions and airborne particulateemissions are filtered and discharged to atmosphere.Non-radioactive effluent is discharged to the public sewer.Liquid foul effluent pumped via the public sewer to Didcot fortreatment prior to discharge to the River Thames. Surfacewater is discharged to the Lydebank Brook. Oils and solventsare disposed of by incineration.Non-radioactive gaseous emissions are discharged toatmosphere.6.2.16.2.26.3.46.3.4RSRL IWS (Issue 5 – October 2012)55

NOT PROTECTIVELY MARKED5.2 Winfrith186. The Winfrith site strategy is to achieve an Interim End State by 2024 when all the ILWhas been packaged into final disposal packages (RCBs) and will have been transferred offthe Winfrith site for long-term storage in the Harwell ILW store. All redundant buildings willhave been demolished and the site will then be passively managed by applying land userestrictions whilst residual radioactivity decays. After a period of time (envisaged to bedecades), the site will reach a condition when it can be de-licensed then de-designated atwhich point the land use restrictions will no longer be required.187. The key milestones related to waste management for achieving the Interim End State atWinfrith are listed below:YearKey Milestone2013 EAST decommissioning complete2015 Blacknoll Reservoir decommissioned2021 DRAGON decommissioned2023 SGHWR decommissioned2023 Sea pipeline decommissioned2022 ILW transferred to Harwell ILW Store2024 Interim End State188. The strategy for waste processing and interim storage is to be consolidated around theA5 and adjacent B5 areas of the site. The A5 area contains the existing liquid waste(including sewage from the western end of the site) collection, treatment and sea dischargesystems, and the solid waste decontamination, size reduction and packaging facilities. TheB5 area contains the Treated Radwaste Store (TRS).189. The processing of sludge arising from the SGHWR resin beds has been completed andthe encapsulated waste is currently being stored in the TRS pending disposal to the LowLevel Waste Repository. WETP has been demolished and the decommissioning of EAST isunderway with only the tank base and sub-base to complete. The treatment of theremaining historic wastes comprising concrete lined drums and uranium will be undertakenusing the SGHWR ILW Processing Plant at the time of decommissioning SGHWR. Thoriummetal at Winfrith will be transferred to Harwell in 200 litre drums for interim storage. Whilstthe baseline strategy for the thorium is to package and grout it into RCBs prior to disposal tothe GDF, RSRL is actively pursuing sale for re-use in the fuel cycle.190. Decommissioning of the two reactors will occur from 2013 to 2023. LLW arising fromdecommissioning will be processed and disposed using existing disposal routes. Thearisings of ILW will require the installation of a Head Cell, an ILW Transfer system and anILW processing plant within SGHWR and Dragon.191. Other waste operations during this time will be the processing of remaining wastes onsite, including a quantity of sodium metal. .Off-site facilities that are a responsibility ofRSRL IWS (Issue 5 – October 2012)56

NOT PROTECTIVELY MARKEDRSRL, such as the Sea Pipeline and the Blacknoll Reservoir, will be decommissioned. Themajority of the area of the remaining site will be restored, the resultant wastes disposed andthe areas delicensed. The delicensing of the A6/A7 area of land at Winfrith was approvedby ONR in July 2012.192. All ILW arising at Winfrith will be packaged and grouted into Robust Concrete Boxes andtransferred to Harwell for long-term storage pending availability of the GDF. Transfers toHarwell are scheduled to commence in 2020 and be complete by 2022.193. The inventory of radioactive and non-radioactive waste in stock or due to arise on theWinfrith site is given in Annex 1. Following the sharing of lessons learned from the MagnoxSMART Inventory exercise with respect to underpinning of waste volumes, RSRL hasundertaken a similar exercise for the Dragon reactor at Winfrith. This exercise will be rolledout across the rest of Winfrith and RSRL over the coming year.194. A summary of Winfrith waste arisings for the main waste categories with current storageand disposal routes is given below and addressed in detail in Section 7.Waste TypeILW Concrete LinedDrumsVolumein m 3 Future storage / disposal route Section4.6 Storage at Winfrith pending packing and 7.1.2.1grouting into RCBs. Transfer to Harwell forlong-term storage in the Harwell ILW storepending transfer to the GDF.Raw ILW(SGHWR and Dragondecommissioning ILWincluding that already instore in SGHWR)395 Package and grout into RCBs and transfer toHarwell for long-term storage in the HarwellILW store pending transfer to the GDFThorium 0.98 Transfer to Harwell in 200 litre drums forinterim storage pending disposal to the GDFunless the opportunity to return it to the fuelcycle is realised.7.1.2.27.1.2.3Other ILW(natural uranium,depleted uranium andredundant sources)LLW in stock across siteand operational arisingsLLW future arisings fromdecommissioningLLW 15 arisings suitablefor landfill3.9 The natural and depleted uranium will bestored in the TRS whilst options for its use areexplored. If it is declared as a waste it will bepackaged in RCBs and transferred to theHarwell ILW store for long-term storagepending transfer to the GDF. There are alsoa number of redundant ILW sources on theWinfrith site which will be sent to Harwell.716 Package in ISO disposal container anddisposal in LLW repository8,335 Package in ISO disposal container anddisposal in LLW repository2,531 Permit granted by Environment Agency toallow disposal to a licensed landfill7.1.2.37.1.37.1.37.1.3.415 Formerly known as High Volume Low Activity (HVLA) wasteRSRL IWS (Issue 5 – October 2012)57

NOT PROTECTIVELY MARKEDWaste TypeSGHWR Sludges(encapsulated)Sodium(bulk metal)RSRL Tenanted LiabilityWasteVolumein m 3 Future storage / disposal route Section534 Stored in TRS pending transfer to LLWR 7.1.3.124 Repackage and send for incineration 7.1.4.1- Managed and disposed of by tenant usingexisting plant and equipment7.1.4.2Non-Radioactive Waste Type Disposal route SectionHazardous waste Collected and disposed to landfill 7.3.1Non-Hazardous wasteRe-used or recycled where possible anddisposed of to a licensed landfill site where this isnot possible7.3.2Inert waste Recycled or re-used on-site 7.3.3Discharges Discharge Route SectionRadioactive liquid Liquid foul and active process effluent - discharged, via the 7.2.1ALES, to sea. Tritiated Groundwater (yet to arise) – will bedischarged to the River Win/Frome. LLW Organic Liquids aresent off-site for incinerationRadioactive gas Gaseous radioactive emissions and particulate airborne 7.2.2emissions – filtered and discharged to atmosphereNon-radioactiveliquidLiquid Discharges - aqueous liquids discharged, via ALES, tosea; organic liquids recycled where possible or sent off-site for7.3.4.1Non-radioactivegasincinerationGaseous Discharges– filtered and discharged to atmosphere 7.3.4.2RSRL IWS (Issue 5 – October 2012)58

NOT PROTECTIVELY MARKED6 HARWELL INTEGRATED WASTE MANAGEMENT STRATEGY195. The Harwell integrated waste management strategy is developed from the results of aseries of decommissioning and waste management option studies and BPEO studies.Optimisation was achieved with the completion of the Harwell site waste BPEO study at theend of 2008. By adopting the BPEO approach for all waste on the site, both radioactive andnon-radioactive, there has been an opportunity for all relevant and interested stakeholdersto be consulted. Issues identified as a result of stakeholder engagement which have aneffect on waste strategy include:• The site end state should be 100% de-licensed to enable sustainable developmentof the site as part of the Harwell Oxford Campus.• The health and safety of workers and public and protection of the environment aretop priorities.• The impact of transport, particularly of radioactive waste, concerns local residents.196. The BPEO process is not the only approach to stakeholder consultation, as described insection 4.6. Regulators have frequent interactions with the site relating to waste strategy.Issues identified as a result of consultation with regulators on waste strategy include:• EA is keen to see evidence and examples of using best practicable means tominimise waste arisings.• ONR (CNS) has been consulted and has given advice on security issues relating tothe development of the waste strategy.• Consultation with NDA has resulted in encouragement or, where appropriate,approval for specific waste strategies.197. Going forward, BPEO and BPM studies will be replaced by BAT studies in order tocomply with the Environmental Permitting Regulations 2010.198. Annex 1 summarises the inventory of wastes in stock or expected to arise at Harwell andcontains the following information:• A description of the waste• Estimated waste quantities• When the waste is expected to arise• When and where the waste will be processed• When and where the waste will be stored• When and where the waste will be transferred off-site199. The progress of the strategies for ILW can be established by the status of approvalsfrom RWMD for the proposed packaging routes against the requirements for safe disposalunder the phased disposal concept. The definitions of the stages of Letter of Complianceare as follows:• Conceptual LoC: presents known information regarding the waste, the proposedconditioning method and process, and the expected average and maximum packageproperties. This stage takes place before resources are committed to a wastemanagement strategy. Action points may accompany a Conceptual LoC which willneed to be completed by the Interim or Final submission.• Interim LoC: presents further information on the waste, method of conditioning andresults of waste form trials. It describes the facility and conditioning process indetail.RSRL IWS (Issue 5 – October 2012)59

NOT PROTECTIVELY MARKED• Final LoC: presents information on commissioning of the waste packaging plantalong with documentation to demonstrate that the action points from earliersubmissions have been closed out.6.1 Radioactive Wastes200. The inventory of radioactive waste at Harwell is given in Annex 1 and a summary of thevolumes expected to be generated is given below.Waste Type Volume (m 3 )HLW 0ILW 2,788*LLW 10,115LLW to Landfill 24,148* includes 169.5m 3 packaged ILW201. The total ILW volume has increased slightly from the March 2012 IWS following a reviewof Concrete Lined Drums undertaken as part of the NM transfers and the reassessment oflegacy sludges.202. The overall strategy for radioactive wastes is treatment as necessary to allow removalfrom the site. This will largely be achieved by disposal via authorised disposal routes orconversion to a passively safe state for long term storage on-site prior to disposal to theGDF.203. The Clearance and Exemption Code of Practice has been produced to identify andfacilitate good practice within the nuclear industry regarding the clearance and sentencing ofarticles, substances and wastes which may or may not require disposal as radioactivewaste. The Code of Practice has been developed and agreed by representatives from thenuclear industry and the Harwell site has established and maintains arrangements to complywith the code.6.1.1 High Level Waste204. There is no high level waste on the Harwell site.6.1.2 Intermediate Level Waste205. Estimates of current stocks and future arisings of ILW are given below. Strategies forILW and their status are also summarised. They are either:• Operational: Strategy agreed and being implemented or• Reference: Selected as the current preferred strategy against which other strategiescan be comparedRSRL IWS (Issue 5 – October 2012)60

NOT PROTECTIVELY MARKEDILWArising /UnprocessedVolume m 3PackagedVolume m 3Strategy (status and description)Historic RHILWarisings to beretrieved from tubestores in SolidWaste Complex118.9(raw volumeremaining to beprocessed)302(totalpackagedvolumewhen allwasteprocessed)Operational (Final LoC approved) RHILW retrievedfrom tube stores is processed and packaged into 500-litre drums using the Head End Cell (HEC) in theSolid Waste Complex. The drums will be filled withcement grout in the Waste Encapsulation Plant(WEP) due to be commissioned by 2014. The filleddrums will be stored in the Vault Store until transfer tothe GDF.Historic RHILWarisings alreadyretrieved fromtubes stores andcurrently in storeawaiting furtherprocessingNuclear materialRadioactiveSources76(volume in500 litre drums)2.4(raw volumeremaining to beprocessed)* Includedabove* Includedabove

NOT PROTECTIVELY MARKEDILWArising /UnprocessedVolume m 3PackagedVolume m 3Strategy (status and description)ImmobilisedLegacy ILWSludges0 13in 500-litredrumsOperational (Final LoC implemented). All ILWsludges have been immobilised into 500-litre drumsand will be stored in the Vault Store long-term untilthe GDF is available.ILW from reactordecommissioning470(incl 360m 3graphite)3,094in RCBsReference (need LoC). BEPO, DIDO and PLUTOdecommissioning ILW will be packaged into RCBsand transferred to the Harwell ILW store for long-termstorage until the GDF is available. A CLoCsubmission will be made shortly.Concrete LinedDrumsLarge NDSsources(too large or heavyfor 500 litre drums)Uranic residues(Depleted andNatural Uranium)Low enricheduranium1061 N/A Reference (part of NM project). Transfer to Sellafieldusing a combination of the TN Gemini package andFull Height ISO container. The drums will be put inlong term storage at Sellafield pending processingand packaging via a new waste treatment plant priorto disposal to the GDF.1.8 3 Reference (need LoC). Sources will be packagedinto 3m 3 boxes and grouted in the current storagefacility. The grouted boxes will be stored in a securearea pending final disposal to the GDF.5.2 31 Reference (need LoC). Natural and depleteduranium will be repacked and immobilised into 500litre drums and will be stored in the Harwell ILW storeuntil the GDF is available.12.9 N/A Reference (part of NM project). Transfer to Sellafieldusing the Novapak container. The drums will be putin long term storage at Sellafield pending processingand packaging via a new waste treatment plant(WTC2) prior to final disposal to the GDF.The above is the fallback strategy as the preferredoption of recovery has not been agreed.Historic CHILW indrums includingCHILW arisingsfrom Solid WasteComplexdecommissioningDecommissioningCHILW arisings(excluding SolidWaste Complex)807 N/A Reference (part of NM project). Transfer to Sellafieldusing a combination of Nupaks, Novapaks and FullHeight ISO containers. The drums will be received into the Engineered Drum Store at Sellafield. Suitabledrums will be compacted into pucks and grouted into500 litre drums at the Sellafield Waste TreatmentComplex before returning to the EDS for long termstorage pending disposal to the GDF. Noncompactabledrums will be stored in the EDS pendingprocessing and packaging via a new waste treatmentplant prior to disposal to the GDF.34 112 Reference (need LoC). Decommissioning CHILW willbe packaged and grouted into 3m 3 boxes followed bylong-term storage in the Harwell ILW Store pendingavailability of the GDF.RSRL IWS (Issue 5 – October 2012)62

NOT PROTECTIVELY MARKED206. The strategy for ILW has three main aspects:• RHILW is being packaged into 500-litre drums then grouted in WEP before long termstorage in the Vault Store. The Vault Store also stores encapsulated legacy LETPliquors and sludges;• CHILW in drums and Concrete Lined Drums will be transferred to Sellafield foronward processing and disposal along with Dragon Waste and Low EnrichedUranium as part of the Nuclear Materials Transfer project.• Reactor decommissioning ILW will be processed, packaged and grouted into RobustConcrete Boxes.6.1.2.1 RHILW packaged and grouted into 500-litre drums207. RHILW in stock and future arisings will be packaged into 500-litre drums in the HeadEnd Cell (HEC) in the Solid Waste Complex. Sources of ILW include:• Historic RHILW to be retrieved from the tube stores• Waste Requiring Additional Treatment• Nuclear material such as GLEEP fuel and Zenith fuel• Radioactive sources from the former National Disposal Service (NDS), Winfrith, andthe EA Sealed Source Disposal Programme• RHILW from decommissioning the Active Handling Facility.208. The majority of historic RHILW arisings were produced during research anddevelopment work relating to civil nuclear energy production and the nuclear fuel cycle. Dueto the nature of the work the wastes are very heterogeneous and in some cases the recordsare limited. There is a programme of retrieval, processing and repackaging through theHEC in the Solid Waste Complex. Bespoke retrieval machines (RM1 and RM2) are used torecover wastes in steel cans from the older tube stores. The retrieval machines are requiredbecause it is known that some of the steel containers, which have been stored for up to 40years, have failed. A third tube store is relatively modern (1990) and is used for the interimstorage of waste in stainless steel cans and employs a Gamma Gate to receive and recoverwaste. Once recovered, the majority of the wastes are processed and assayed in the HECand packaged into 500-litre drums in accordance with the requirements stipulated by theRWMD LoC. Filled drums are stored, ungrouted, in the Vault Store pending immobilisationin the Waste Encapsulation Plant (WEP), which is currently being commissioned.209. A proportion of the historic RHILW will require additional treatment, such as sizereduction, grouting of liquids / fines or immobilisation in polymer, before it can be packaged.These wastes are referred to as Wastes Requiring Additional Treatment (WRATs), some ofwhich are currently in temporary storage in 500-litre drums pending processing via the HeadEnd Cells in the future.210. A number of WRATs have already been treated including the clay encapsulation of finesin the Head End Cells and the immobilisation of radium wastes in polymer or cement groutin the Radiochemical Building. With the cessation of operations in the RadiochemicalBuilding all remaining WRATs will be processed via the Head End Cells.211. Nuclear materials may need to be treated before packing and grouting into 500 litredrums.• RSRL has a Final LoC from RWMD for GLEEP fuel and this waste is currently beingimmobilised in polymer in its current containers prior to placing it into 500-litre drumsready for final immobilisation in cement in WEPRSRL IWS (Issue 5 – October 2012)63

NOT PROTECTIVELY MARKED• RSRL has a Final LoC from RWMD for Zenith fuel, which is currently being copackagedwith RHILW in 500-litre drums ready for immobilisation in cement in WEP212. Sources which arose via the former National Disposal Service (NDS) will be sizereduced by removal of inactive shielding if necessary before packaging. Some sourceshave been transferred from Winfrith and up until 2014 Harwell will continue to process lowlevel radioactive sources from the Sealed Source Disposal Programme.213. Large non-gaseous NDS sources that are too large or heavy to be placed into a 500-litredrum will be packaged into 3m 3 boxes and grouted in their current storage facility. Thegrouted boxes will be place in on-site long-term storage in a secure area pending finaldisposal to the GDF.214. A small volume of RHILW is estimated to arise during the decommissioning of the ActiveHandling Building. This will be packaged through the Head End Cell and WEP with legacyRHILW from the SWC. The majority of this waste is covered by the Letter of Compliance forRHILW.215. Legacy ILW liquors and sludges have been conditioned in the LETP immobilisation plantand are stored in the Vault Store until transfer to the GDF.6.1.2.2 Dragon Waste, Drummed CHILW, Concrete Lined Drums and Uranic Residues fortransfer to another NDA site.216. Dragon Waste consists of Highly Enriched Uranium micro-spheres containing heavymetal (U, Th & Pu) oxides and carbides coated in ceramic and carbon, mixed with graphiteand made into compacts. These compacts are currently stored in 251 stainless steel cansknown as ‘Third Length Containers’ (TLC’s).217. The strategy for Dragon Waste is to transfer it to Sellafield as part of the NM project.The proposal is to transfer two TLCs at a time in a 1.5 Modular Flask. The TLCs will bereceived in to the Magnox Encapsulation Plant cells for encapsulation in to 500 litre drumsfollowed by a period of long term storage pending final disposal in the GDF.218. The Contact Handled LW in drums consists mainly of plutonium contaminated materialbut also includes other ILW with radiation levels

NOT PROTECTIVELY MARKED221. The CLDs will be placed in long term storage at Sellafield pending processing andpackaging via a previously planned waste treatment plant at Sellafield, pending finaldisposal to the GDF.222. The site waste BPEO Study determined direct encapsulation at Harwell to be the highestscoring option for the management of CHILW in drums and concrete lined drums, withsupercompaction at Harwell and Sellafield a close second and third respectively. Sincecompletion of this BPEO study, options for processing and storage of nuclear materials atSellafield have become more technically feasible. A BAT assessment including severaloptions in addition to those considered in the BPEO study has been carried out to underpinthe NM transfers programme. A summary of the changes to the preferred option for the NMstream as a result of the BAT assessment will be shared with local stakeholders.223. In the site waste BPEO study the preferred option for the management of low enricheduranium (LEU), natural uranium and depleted uranium was identified as recycling of thematerial in the UK. RSRL has looked into the possibility of transferring the LEU toSpringfields for processing through their Enriched Uranium Residues Recovery Plant,however, due to no handshake being achieved between RSRL and Springfields, thereference strategy has been processing and encapsulation on site followed by long-termstorage. Whilst this remains the strategy for stocks of natural and depleted uranium thestrategy for LEU is to transfer it to Sellafield as part of the NM project.224. The proposal is to transfer LEU drums using the Novapak container and receive theminto the THORP UO3 Store at Sellafield. The drums will remain in long term storagepending processing and packaging via a new waste treatment plant (WTC2) prior to finaldisposal to the GDF. It should be noted that the transfer of LEU to Springfields is stillidentified as an opportunity in the current LTP baseline. The volumes of uranium at Harwellare small compared to the rest of the nuclear industry and there is also an opportunity forNDA to formulate a nationwide strategy for uranic residues.6.1.2.3 Reactor Decommissioning ILW225. For the reactors on the Harwell site the preferred option in the site waste BPEO studywas to delay decommissioning until 2040. However this strategy is not consistent with theHarwell site programme to achieve a passive safe state and it also leaves adecommissioning liability to a future generation. The reference strategy for ILW arising fromthe decommissioning of the reactors, BEPO, DIDO and PLUTO, is therefore packaging intoRCBs prior to 2030. Some 361m 3 of reactor decommissioning ILW is graphite and will beheat treated so that any Wigner energy is released before packaging for disposal. Work willbe done during the planning and preparation phase of decommissioning to determinewhether annealing is required and whether some of the waste could subsequently beconsigned as LLW. The graphite will therefore be stored in an un-encapsulated form, asdetermined to be the preferred option in the site waste BPEO study, until decisionsregarding annealing and grouting have been finalised. Nevertheless the boxes are plannedto be stored in the Harwell ILW store until they are transferred to the GDF.226. A major assumption in the current LTP baseline is the availability of the GDF for ILWdisposal. The location for the GDF has not yet been identified but it is assumed to beavailable from 2040. Scope, schedule and costs for the long-term storage of ILW on theHarwell site are included in the current LTP, as are the transport costs from Harwell to theGDF.RSRL IWS (Issue 5 – October 2012)65

NOT PROTECTIVELY MARKED6.1.2.4 CoRWM227. The Government has announced its agreement to the conclusions of CoRWM's workrecommending geological disposal for the longer term management of UK's higher activitywaste. NDA has been given responsibility for developing and ensuring delivery andimplementation of the programmes for interim storage and implementing geologicaldisposal. RSRL strategies for ILW assume interim storage until the GDF becomesavailable. NDA's work on interim storage could change the interim storage assumptions infuture.228. Figure 6 summarises the strategy for ILW at Harwell:RSRL IWS (Issue 5 – October 2012)66

NOT PROTECTIVELY MARKEDEncapsulated LETPLiquors & SludgesAHF DecommissioningRHILWStored ILW(from tube storesincluding WRATs andsources)SWC HECPackage ILW into500-litre drumsSWCVault StoreStored Nuclear Material(GLEEP/Zenith)Grout in WEPRHILW non-gaseousNDS sourcesRHILW non-gaseousNDS sources(unsuitable for 500 litredrums)Package andgrout ILW into3m 3 boxesStore in SWCTransport toGeologicalDisposalFacilityCHILW non-gaseousNDS sourcesRepack intogalvanised drumsOverpack3m3 boxesinto SWTCsPackage &groutDU/NU into500 litre drumsRCF DecommissioningCHILWPackage & groutinto 3m 3 boxesILW from ReactorDecommissioning(BEPO, Dido & Pluto)Package & groutinto RCBsLong termstorage inHarwell ILWStoreDepleted and NaturalUraniumDrummed CHILWincluding waste fromSWC DecommissioningConcrete Lined DrumsDRAGON FuelFHISO/Nupak/NovapakFHISO/TN-GeminiModularWinfrith ILW ingrouted RCBsTransport toSellafield forprocessingand disposalLEUNovapakopportunityRecovery atSpringfields for re-useRSRL IWS (Issue 5 – October 2012)Figure 6: Harwell ILW Strategy67

NOT PROTECTIVELY MARKED6.1.3 Low Level Waste229. Low level waste (LLW) on the Harwell site consists of:• solid waste routinely consigned to the LLWR,• waste sent off-site for incineration and• low level waste suitable for landfill including high volume very low level wasteThe strategy is to minimise the production of LLW by application of the waste hierarchy.Examples include:• the decontamination of lead, by planing, to reuse or recycle;• the use of characterisation techniques to enable wastes to be characterised asexempt (‘out of scope’) waste;• the use of a “blast and vacuum” technique to decontaminate the surface of a buildingand• the use of the abrasive cleaning machine at Winfrith (WACM) to decontaminatemetal for recycling.230. Estimates of current stocks and future arisings of LLW are given below.LLWOperational LLW stocks andarisings (0.4 - 4,000Bq/g alpha and0.4 - 12,000Bq/g beta/gamma)Arising /UnprocessedVolume m 3PackagedVolumem 3Legacy LETP Sludges 0 0Decommissioning LLW arisings(0.4 - 4,000Bq/g alpha and0.4 - 12,000Bq/g beta/gamma)Strategy1651 3210 Disposal to LLWR. Volumes aftersegregation of exempt (out of scope)waste.All sludges have been processed anddisposed to LLWR8,464 16,542 Disposal to LLWR. Volumes aftersegregation of exempt (out of scope)waste.Graphite 0.4 - 4Bq/g 0 N/A All sent for Incineration.Oils / Solvents 0.4 - 4Bq/g 1 N/A Incineration.Low Level Waste to Landfillup to 200Bq/gVery Low Level Waste0.4 - 40Bq/g24,148 N/A Off-site disposal to permitted landfill.Building rubble and soil too radioactivefor reuse.231. The volumes of LLW reported above assume that all exempt (‘out of scope’) waste hasbeen segregated from the LLW sent to the LLWR. The exempt (‘out of scope’) waste ischaracterised and consigned in compliance with the Nuclear Industry Code of Practice onClearance and Exemption.232. RSRL is developing alternative routes for LLW in accordance with the actions listed inthe Joint Waste Management Plan. Of particular interest are off-site treatment routes forsegregated metals and combustible materials. RSRL is currently exploring the option ofsmelting metallic LLW and have identified some drums of suitable waste at Winfrith forwhich LLWR have quoted for treatment overseas. Transfer of this waste via the LLWRframework supplier contract is due to take place by the end of 2012. A route for disposal ofVLLW and LA-LLW at an off-site landfill have been in place for Harwell waste since March2012 and RSRL is working to establish this route for Winfrith wastes as well.RSRL IWS (Issue 5 – October 2012)68

NOT PROTECTIVELY MARKED233. Government announced its new policy on low level radioactive waste management inMarch 2007. The policy includes revised regulation around the disposal of LLW to landfilland allows RSRL to dispose of high volume very low level waste (up to 4Bq/g except fortritium which is allowed up to 40Bq/g) and LLW (up to 200Bq/g) via this route rather than toLLWR at Drigg (see section 6.1.3.3.)234. GLEEP concrete, which has been stored on the Harwell site for a number of years, hasnow been reused on-site as infill material.6.1.3.1 Disposal to the LLWR near Drigg235. Since a large proportion of the LLW at Harwell is or will be consigned to the LLWR, thestrategy is to minimise the volumes of LLW by application of the waste hierarchy and wasteminimisation using best practicable means. The waste with no option but to be consigned tothe LLWR consists mainly of solid LLW and small volumes of sludges and liquors from thetreatment of low level liquid effluent or trade waste which are converted into a solid beforeconsignment. The recommendation from the site waste BPEO study was to continue withdisposal of this waste to the LLWR near Drigg.236. Low level waste arising on site is either collected in drums for processing or packageddirectly into half height ISO disposal containers (HHISOs). Non-compactable LLW collectedin drums is packaged directly into HHISOs. Compactable waste in drums is sent to theWAste Monitoring And Compaction (WAMAC) Facility at Sellafield or the supercompactorowned by Inutec at Winfrith. Supercompacted pucks are placed in HHISOs and transferredto the LLWR for grouting and disposal. Supercompaction reduces the disposal volume andproduces an improved wasteform.237. Low level liquid, containing higher levels of activity than standard low level liquid effluent,is collected in containers known as carboys. The liquid, together with floc from thetreatment of standard low level liquid effluent, is solidified and conditioned by immobilisationin a lost-paddle cementation plant at the LETP. Drums containing conditioned cementedwaste are placed in HHISOs with other bulk waste and consigned to the LLWR.238. The processing of Low level legacy LETP sludges in the LETP encapsulation plant hasbeen completed and the waste disposed to LLWR. During the retrieval process, one tankwas found to contain sludges in excess of the conditions for acceptance at LLWR andtherefore have been re-categorised as ILW. These sludges have been encapsulated and willremain in interim storage in the Solid Waste Complex pending final disposal to the GDF.239. There are a number of drums of stabilised waste arising from the remediation of theWestern Storage Area that contain radioactivity at levels too high to be consigned asexempt (‘out of scope’) hazardous waste. They have been stabilised by solidification incement to produce a monolithic waste form. Initial leach tests have been carried out. Thesewastes are not suitable for disposal to the LLWR however they will be acceptable to thenewly established LA-LLW and HV-VLLW landfill route (see section 6.1.3.3).6.1.3.2 Incineration240. An additional LLW disposal route is incineration at a commercial incinerator with anEPR2010 permit. Wastes consigned via this disposal route include low level organic liquidssuch as oils and solvents, which are collected in carboys, filtered and analysed beforetransfer off-site for incineration. The recommendation from the site waste BPEO study wasto continue with incineration of these waste streams.RSRL IWS (Issue 5 – October 2012)69

NOT PROTECTIVELY MARKED241. For certain wastes the cost of incineration is high, and therefore RSRL is currentlylooking into alternative treatment options for oils and solvents. Any change in strategy forthis type of waste will be documented in future revisions of the IWS.242. Consideration has been given to incineration of the graphite from other reactors, such asBEPO, but the radioactivity levels involved are too high. Plans are being developed toincinerate woodwork, such as doors, arising from decommissioning that cannot beconsigned as exempt (‘out of scope’) waste thereby negating the need for disposal to theLLWR and a high-level strategic BAT review has recently been undertaken. RSRL hasaccess to commercial incineration facilities through the contract with LLWR.6.1.3.3 Low Activity LLW (LA-LLW) and High Volume Very Low Level Waste (HV-VLLW)243. As part of its new policy for LLW, Government has given new definitions for the loweractivity end of the LLW, namely giving the two new categories of Low Volume and HighVolume Very Low Level Waste (VLLW). The activity of high volume VLLW can be up to4Bq/g except for tritium which is allowed up to 40Bq/g. The activity limits for LA-LLW aredependent on the conditions for acceptance given on the permit held by the receiving site.In the case of the off-site route established in the last year this is up 200Bq/g. LA-LLW andHV-VLLW comprises building rubble and soil from decommissioning and site remediation.244. With a large volume of LA-LLW and HV-VLLW arising from decommissioning and landremediation alternatives to disposal at LLWR have been considered and a route establishedin early 2012. This route is being successfully utilised by the Harwell site and its continuedavailability is a key issue for the organisation.245. Figure 7 summarises the strategy for LLW at Harwell:RSRL IWS (Issue 5 – October 2012)70

NOT PROTECTIVELY MARKEDCompactable LLWSolid LLWMetallic LLWvia SWCLLW OpsTransfer fortreatmentCombustible LLWsecondary wastes andcompacted LLWNon-Compactable/Bulk LLWvia SWC LLW OpsTransfer toLLWROrganic LiquidLLWOff-site incinerationLegacy SludgesLLWLETPEncapsulationPlantEncapsulatedSludgesLLWLA-LLW andHV-VLLW fromdecommissioningand landremediationOff-site Landfilldisposal facilityFigure 7: Harwell LLW StrategyRSRL IWS (Issue 5 – October 2012)71

NOT PROTECTIVELY MARKED6.2 Radioactive Discharges6.2.1 Radioactive Liquid Discharges246. The volumes of all types of liquid effluent have decreased significantly over the past 15years as Harwell has moved from a predominantly research and development site todecommissioning and waste management as its core business.247. The strategy for the management of effluent reduction at Harwell was reviewed andrevised in 2005. A survey of arisings from the Harwell site indicated that liquid effluentcurrently received by RSRL can be considered to fall into one of three categories:• Clean effluent which cannot contain any radioactivity (RSRL buildings and facilitiesproduce inactive trade waste and foul waste, both of which are discharged to thepublic sewer)• Non-treatable active effluent which could contain very low levels of radioactivity butat levels for which treatment gives no benefit in terms of decontamination• Treatable active effluent with levels of radioactivity sufficient for decontamination tobe a viable treatment.Surface water is discharged to the Lydebank Brook248. The main sources of active effluent requiring treatment are from operations in thepressurised suit and decontamination areas of the Solid Waste Complex. Non-treatableactive effluent arises from operations in the Solid Waste Complex, Radiochemical Buildingand Active Handling Facility. There is an ongoing programme of effluent segregation inorder to reduce the volumes of effluent in each category. This constrains consignors to usethe appropriate effluent discharge route so that inactive effluent is excluded from activeeffluent streams, for example non-active “trade” effluent is discharged to the foul drain andshower effluent volumes are minimised.249. Following recent approval by Thames Water, sampled non-treatable active effluent, suchas RSRL trade waste, can now be discharged direct to the public sewer as well as via thedischarge pipeline. This follows the granting of the revised EA Radioactive SubstancesPermit for Harwell in November 2011. Discharge to the public sewer will enable thedecommissioning of the LETP and the Sutton Courtenay Discharge Pipeline to take place asplanned.250. Following the decommissioning of the Main Active Drain during 2011, treatable activeeffluent is currently transferred to the LETP via tanker, warboys or Intermediate BulkContainers. Once at the LETP it undergoes a physical/chemical treatment (flocculation)which adjusts the chemical content and removes sufficient radioactivity to discharge theresulting effluent to the River Thames via the Sutton Courtenay discharge pipeline or, aswith non-treatable active effluent, direct to the public sewer. With the reduction in thevolume of this effluent RSRL are currently commissioning a new treatment plant, known asthe Replacement Effluent Treatment Plant (RETP), which will discharge effluent direct tothe public sewer and solidify LLW sludge for disposal to LLWR. The operation of the RETPwhich will enable the existing treatment plant and discharge pipeline to the River Thames tobe decommissioned.251. In addition to the planned BPEO study mentioned above, the strategy for radioactiveliquid discharges was covered in the BPEO review carried out in 2006 at the request of EA.Radioactive liquid discharges were also included in the site waste BPEO study.RSRL IWS (Issue 5 – October 2012)72

NOT PROTECTIVELY MARKED252. Key stakeholders involved with radioactive liquid effluent strategy include:• Consignors from RSRL facilities - they have been extensively consulted during thedevelopment of the radioactive liquid effluent strategy for the site• Thames Water - a key recipient of the effluent from the Harwell site who haverecently given approval for the discharge of effluent to the public sewer• Tenants and neighbours - they no longer discharge via RSRL facilities butdischarge directly to Thames Water via the cross-site sewer• EA - has been consulted during the development of strategy and have granted aPermit for discharge of effluent to the public sewer• Local stakeholders in the vicinity of the Sutton Courtenay pipeline - they will beconsulted with respect to the decommissioning of the discharge pipeline.Decommissioning plans have been developed and options studies are under way.253. Research and technology developments of the radioactive liquid effluent strategy includeoption studies and feasibility studies for the replacement active effluent plant and optionstudies for decommissioning the discharge pipeline. It is intended that an initial 700msection from the site to the break tank will be dug up and examined first in order to informstudies and consultation regarding the methodologies to be applied for the lower sections,where there is potentially greater impact on local services and communities.254. Plans to meet the requirements of the National Radioactive Discharge Strategy involvean ongoing programme of effluent minimisation through application of BAT. Effluentvolumes will reduce and eventually stop as facilities cease to operate and decommissioningacross the site progresses and appropriate changes to the treatment processes anddischarge routes will be effected to reflect the changing needs. Following the issue of thenew permit by the EA it is intended that non-treatable effluent will be discharged via thepublic sewer rather than the discharge pipeline once consent has been obtained fromThames Water.255. Figure 8 summarises the strategy for liquid wastes from Harwell:RSRL IWS (Issue 5 – October 2012)73

NOT PROTECTIVELY MARKEDSurface water fromacross site(non-radioactive)Surface waterdischargedinto LydebankBrookClean & Foul effluentfrom across site(non-radioactive)Tenant trade wasteeffluent from acrosssiteRSRL trade wasteeffluent from acrosssitedirectPublicSewerTreated at Didcotsewage worksprior to dischargeNo longer in use butnot yet disconnectedDischargePipelineDischarge toRiver ThamesNo longer in use butnot yet disconnectedTreatable activeeffluent fromacross site (via tanker)preRETPLiquid EffluentTreatment PlanttreatedeffluentPublicSewerpostRETPRETPtreatedeffluentPublicSewerLow level flocsolidifiedsludgeLLWRLow LevelActive LiquorLost PaddleCementation PlantLLWR(via Solid WasteComplex)Stored LowLevel SludgeFigure 8: Harwell Liquid Waste StrategyRSRL IWS (Issue 5 – October 2012)74

NOT PROTECTIVELY MARKED6.2.2 Radioactive Gaseous Discharges256. Harwell was authorised under the Radioactive Substances Act 1993 (RSA) for thedischarging of waste gases, mists and dusts to atmosphere; on 6 April 2010, thisauthorisation automatically became an environmental permit under EPR2010. Gaseouswastes are sampled at the point of discharge and the results analysed and reported on afour weekly basis to EA. The site keeps discharges to a minimum through the use of BPMand there has been a decrease in the activity discharged each year. Sources of radioactivegaseous discharges include:• tritium from the Material Testing Reactors (MTRs)• tritium, radon, alpha and beta from the Solid Waste Complex• radon, alpha and beta from the Radiochemical Building257. Gaseous wastes are controlled by ventilated containment incorporating HEPA (HighEfficiency Particulate in Air) filters which remove particulates and are subsequently disposedof as LLW. There is no abatement of tritium, krypton or radon before discharge toatmosphere, as this is not practicable. No change is planned to the treatment of radioactivegaseous discharges prior to achieving the site end state and there will be no futuredischarges once the site end state is achieved.258. Radioactive gaseous discharges were covered in the BPEO review of wastes on theHarwell site carried out for EA in 2006. They were also included in the site waste BPEOstudy during which the current strategy of physical separation/filtration was identified as thesole practicable option. Radioactive gaseous discharges are controlled on a facility byfacility basis and there are authorised limits for each building. Thus there are nodependencies between facilities although there is a total site discharge limit for each nuclideor group of nuclides.259. Key stakeholders include EA, ONR, local residents and critical groups for radiationexposure. EA is consulted on environmental issues and ONR is consulted on safety issueswith respect to the discharges of radioactive gases. An annual report is made to the LocalStakeholder Group and includes data on past discharges and future predicted discharges.260. There is an assumption that the discharge permits will be sufficient to meet operationalrequirements during decommissioning and that best practicable means will be applied tominimise the levels of radioactivity discharged. Constraints relating to radioactive gaseousdischarges impact mainly on the treatment of tritium sources in the Solid Waste Complex.Historic records indicate that the current strategy of releasing tritium to the atmospherecould cause annual discharge limits to be exceeded. Work is in progress to revisit theinventory and to determine if the permitted limit needs increasing.261. For the MTRs an assessment of the discharges during decommissioning will be needed.There is a risk that the tritium levels may exceed authorised limits.262. Research and technology developments include the assessment of radioactivedischarges to atmosphere during the decommissioning of the MTRs. This will be carried outduring the front end engineering phase. Interfaces with other waste streams include tritiumsources in the ILW stream from which the tritium needs to be released before packagingand conditioning into 500-litre drums. The HEPA filters used to filter particulates from air aredisposed of as LLW.263. Plans to achieve the commitments and milestones contained within the NationalRadioactive Discharge Strategy involve the minimisation of discharges through applicationof best practicable means. At times it may be BPEO to increase the radioactive dischargesRSRL IWS (Issue 5 – October 2012)75

NOT PROTECTIVELY MARKEDto atmosphere during decommissioning but the discharges will eventually cease once thesite end state has been achieved.6.3 Non-Radioactive Wastes and Exempt (‘Out of Scope’) Wastes264. The strategy for non-radioactive wastes at Harwell is guided by the waste hierarchy, theapplication of sustainable practices and compliance with the Inter Industry Code of Practiceon Clearance and Exemption. By application of the Waste Hierarchy, waste volumes areminimised and material is reused or recycled wherever possible. As a last resort waste isdisposed of into the environment in a controlled manner.265. Documents that cover the management of solid and liquid exempt (‘out of scope’)wastes include the Harwell procedure “Management of Non-Radioactive Waste”, the Harwell“Quality Programme for the Disposal of Radioactive Waste and Waste Generated withinAreas with the Potential for Radiological Contamination”, and the RSRL standard for the“Clearance of Exempt Material”.266. Radiologically clean and waste exempt (out of scope) from definition as radioactivesubstances is managed contractually on a project by project basis, often using a supplierwith access to a specialist waste management contractor. Nevertheless every effort ismade to share best practice between projects on the site and with other NDA sites. Indecommissioning projects, the strategy is to strip out certain wastes that would preventother materials from being reused. Thus materials such as glass, plastics, wood andasbestos are removed during “soft strip” from building materials which can then be crushedand reused. This minimises the requirement to purchase clean material to bring on site tofill voids produced during clean-up operations. Soil removed during site remediation andcharacterisation and found to be clean is replaced in its original location. Use of material asin-fill requires exemptions under the waste management licensing regulations.267. The management strategy for contaminated land is documented in the Land QualityStrategy for Harwell produced for NDA in 2006.6.3.1 Hazardous Non-Radioactive Waste268. Hazardous waste under the Landfill (England and Wales) Regulations 2002 includes anywaste as defined in Article 1(4) of Directive 91/689/EEC (hazardous waste). Beforehazardous waste can be consigned for disposal it needs to be pre-treated, which caninvolve characterisation, segregation or conditioning. Estimates of current and futurearisings of hazardous non-radioactive waste are given below. All current wastemanagement routes for hazardous non-radioactive waste are consistent with the preferredoptions identified in the site waste BPEO study unless otherwise indicated below.TypeAsbestosLeadZinc BromideMercuryOils and solventsChemicalsOffice wastesWSA wastes(LLW)Other (misc)Waste Management RouteDisposal via a specialist contractorRecycleRecycleDisposal via a specialist contractorIncinerationStabilisation and disposal via a specialist contractorDisposal via a specialist contractor; recycle batteries andother materials as far as possibleWaste already stabilised, disposal to LLW landfillDisposal via a specialist contractorRSRL IWS (Issue 5 – October 2012)76

NOT PROTECTIVELY MARKED269. A major source of hazardous non-radioactive waste is asbestos which arises primarilyduring decommissioning operations. The asbestos is removed under controlled conditionsand sent to a specialist disposal contractor.270. Bulk lead is used extensively for shielding and where possible the strategy is to removeany radioactivity as lead shavings and consign them to the LLWR. The remaining clean orexempt (‘out of scope’) bulk lead is recycled by selling directly to the marketplace.271. Routine hazardous wastes arising from the office environment, such as batteries andprinter cartridges, are managed under the site-wide Facilities Services Contract.272. Zinc bromide is used in shield windows. Records and experience show that the zincbromide at Harwell should not be contaminated. When the time comes to dispose of thezinc bromide, a sampling and monitoring regime will be devised to confirm that it can berecycled via a specialist contractor. If recycling is not possible, incineration will be pursued,as recommended by the site waste BPEO study.273. Small quantities of mercury are expected to arise during decommissioning operations.Items will be monitored and sent to a specialist contractor for disposal at a hazardous landfillafter first consolidation with any similar materials from Winfrith. In the site waste BPEOstudy, re-use was identified as the preferred option for mercury. However it would benecessary to secure a third party willing to accept the material for re-use hence the fallbackoption of disposal at a hazardous landfill will continue. Contaminated mercury is identifiedas an orphan waste by LLWR and development of a route for this waste is currently anaction under the National Waste Programme.274. The strategy for oils and solvents is incineration and a permit in place for commercialincineration via the LLWR contact. Chemicals are stabilised as appropriate and consignedto a specialist disposal contractor.6.3.2 Non-Hazardous Non-Radioactive Waste275. Non-hazardous waste covered in this section is the material that is neither hazardousnor inert under EPR2010. It includes plastics, glass, wood and building rubble not suitablefor reuse. Management routes for non-hazardous non-radioactive waste are given below.TypeMetalOffice wastesSoft StripWaste Management RouteRecycleRecycle paper cardboard, plastic, books, newspaper and cans.Dispose of non-recyclable office waste.Disposal to non-hazardous landfill276. The strategy for non-hazardous waste is to recycle where possible and to minimise thevolumes consigned to landfill. This is consistent with the preferred option determined in thesite waste BPEO study.277. The waste produced from excavating the foundations for the new ILW store is expectedto be non-radioactive non-hazardous soil that will be reused as in-fill on-site. Thus there isno requirement for a Site Waste Management Plan as given in DEFRA’s non-statutoryguidance.RSRL IWS (Issue 5 – October 2012)77

NOT PROTECTIVELY MARKED6.3.3 Inert Non-Radioactive Waste278. Inert waste is a sub-category of non-hazardous waste. Under EPR2010 it includes anywaste that does not undergo significant physical, chemical or biological transformations. Itdoes not dissolve, burn or physically or chemically react and its leachability and leachate donot endanger the environment. As a result the waste acceptance criteria testing for nongenericinert wastes are more onerous than for non-hazardous waste. Management routesfor inert non-radioactive waste are given below.TypeConcrete /Building RubbleSoilWaste Management RouteConcrete and building rubble is monitored as clean or belowexempt (out of scope) levels and reused on-site as infill wherepossible. Surplus material is sent for disposal to an inertlandfill.Soil is monitored as clean or below exempt (out of scope)levels and replaced or used on-site for landscaping.279. Inert non-radioactive waste consists mainly of concrete or building rubble which can becrushed for reuse as infill on-site. This minimises the requirement to purchase cleanmaterial to fill voids produced during decommissioning. Use of material as infill requires anexemption under EPR 2010. This has become managerially more onerous now that theapplication forms require much more detail to be provided to the EA. In addition the EA isrequired to inspect each location/ operation which stretches their resources and causesdelay. Exemptions need to be sought on an individual basis rather than an annual genericbasis for the site. Soil removed during site remediation and found to be clean aftercharacterisation is replaced in its original location or used for landscaping.280. Figure 9 summaries the strategy for non-radioactive waste at Harwell:RSRL IWS (Issue 5 – October 2012)78

NOT PROTECTIVELY MARKEDRecyclablehazardous wasteClean, monitor &recycleZinc BromideHAZARDOUSWASTEOils and solventsMercuryOff-SiteIncinerationDisposal route underdevelopment byLLWRAsbestosSend to hazardouslandfillReusable nonhazardouswasteMonitor &reuseNON-HAZARDOUSWASTERecyclable nonhazardouswasteMonitor &recycleNon-hazardous wasteConsign to inert ornon-hazardouslandfillINERTWASTEReusable concrete,building rubble and soilReuse on siteas infillSurplus sent toinert landfillFigure 9: Harwell Non-radioactive Waste StrategyRSRL IWS (Issue 5 – October 2012)79

NOT PROTECTIVELY MARKED6.3.4 Non-Radioactive Discharges6.3.4.1 Liquid Waste Discharges281. Non-radioactive liquid discharges consist mainly of water and include non-radioactivetrade effluent, foul effluent, surface water and treated WSA groundwater. Trade effluent andfoul effluent are pumped via the public sewer to Didcot and treated prior to discharge to theRiver Thames. By discharging trade and foul effluent via the sewer, rather than directly tothe River Thames, means that there is less environmental impact to the river as thetreatment process improves the quality of effluent.282. Surface water is discharged to the Lydebank Brook. Volumes depend on rainfalltherefore predictions of future estimates cannot be made. Groundwater from the WSA istreated through the WSA Groundwater Containment Plant before being returned to theaquifer under an authorised discharge consent, see section 4.4.2. Volumes treated andtherefore discharged depend on the level of the water table and so cannot be predicted.6.3.4.2 Gaseous Discharges283. Non-radioactive gaseous discharges at Harwell are predominantly associated withheating, and do not include any proscribed substances that require permits under EPR2010.Carbon dioxide is reported under the Nuclear Sector Plan.6.4 Waste Disposal and Transfer Routes284. Permitted Radioactive Waste Disposal Types and Disposal Routes for Harwell aretabulated in Annex 2. See section 4.5.3 for interactions with other site or organisations.285. A contract is in place between RSRL and LLW Repository Ltd for the disposal of LLW atthe LLWR. The contract also provides for treatment services such as supercompaction,metal treatment and incineration, as well as disposal to Permitted landfills. The contractwas renewed in April 2012.286. Supercompactable LLW is generally transferred to Inutec on the Winfrith site forsupercompaction. RSRL has a separate contract with Inutec covering supercompactableLLW from Winfrith and Harwell sites.6.5 Tenant and Third Party Waste287. Some wastes are currently stored at Harwell on behalf of their owners or belong totenants on the site. These do not feature in the current LTP baseline because they are notNDA liabilities. There is a risk to the Harwell strategy that the waste owners could walkaway from their responsibilities and leave Harwell to manage the processing and disposal ofthe wastes at additional cost to the NDA.288. Reviss used to lease a storage pond for its cobalt-60 business. This operation hastransferred off-site and the facility will be decommissioned as part of the RSRL lifetime plan.289. GE Healthcare owned over 100 concrete lined drums most of which are stored in theHarwell Concrete Lined Drum store. Liability for these drums transferred to NDA via acontract signed in 2011. These drums will be included in the programme of NM transfers toSellafield.RSRL IWS (Issue 5 – October 2012)80

NOT PROTECTIVELY MARKED290. In addition GE Healthcare owned some ILW currently stored in the Solid WasteComplex. Again the liability for this waste has been transferred to NDA and the strategy isto process this ILW with RSRL legacy ILW.RSRL IWS (Issue 5 – October 2012)81

NOT PROTECTIVELY MARKED7 WINFRITH INTEGRATED WASTE MANAGEMENT STRATEGY291. This section summarises the strategy for specific groups of waste and theirinterconnection where appropriate. The inventory of existing and future radioactive wastearisings for the Winfrith site is listed in Annex 1 and contains the following information:• A description of the waste• Estimated waste quantities• When the waste is expected to arise• When and where the waste will be processed• When and where the waste will be stored• When and where the waste will be transferred off-site292. For non-radioactive wastes, Annex 1 gives information on proposed re-use andrecycling.293. The detailed strategy for managing the various wastes arising at Winfrith is describedbelow.7.1 Radioactive Wastes294. A summary of the main solid radioactive wastes expected to be generated on theWinfrith site is given in the table below and Annex 1.Waste Type Volume (m 3 )HLW 0ILW 405LLW solid 9051+ 24m 3 sodiumConditioned LLW sludge 534LA-LLW and HV-VLLW to Landfill 2531295. The ILW volume includes less than 1m 3 of thorium metal which will be sold to a thirdparty for return to the fuel cycle. The volume for LLW sludges includes encapsulatedSGHWR sludge.296. The following sections give details of the radioactive waste on the Winfrith site. A sitewideBest Practicable Environmental Option (BPEO) Study was completed in 2006, whichinvestigated waste disposal and waste management processes on the site. The results ofthe BPEO Study have been fed back into the ongoing planning and development activitiesbeing undertaken by the site. Any outcomes or changes in strategy that are not consistentwith the BPEO Study are discussed here under the relevant Sections.7.1.1 High Level Waste297. This type of waste does not exist on the Winfrith site.RSRL IWS (Issue 5 – October 2012)82

NOT PROTECTIVELY MARKED7.1.2 Intermediate Level Waste298. The Government has announced its agreement to the conclusions of CoRWM's workrecommending geological disposal for the longer term management of UK's higher activitywaste. NDA has been given responsibility for developing and ensuring delivery andimplementation of the programmes for interim storage and implementing geologicaldisposal. RSRL strategies for ILW assume interim storage until geological disposalbecomes available. NDA's work on interim storage could change the interim storageassumptions in future.7.1.2.1 Concrete Lined Drums299. There are 7 ILW legacy Concrete Lined Drums (CLDs) stored in two HHISO containersin SGHWR. They will be processed through the SGHWR ILW Processing Plant and groutedinto RCBs prior to transfer to Harwell for long-term storage in the Harwell ILW store pendingdisposal to the GDF. All LLW concrete lined drums have been consigned to LLWR.7.1.2.2 Decommissioning ILW300. ILW will be generated during the decommissioning of the Dragon and SGHWRReactors. Appropriate facilities will be constructed for the removal, process and packagingof the ILW. Where possible, ILW will be decontaminated to allow it to be treated as LLW,but where this is not possible the ILW will be grouted in Robust Concrete Boxes within ashielded facility constructed in the Dragon Complex for Dragon wastes and within a shieldedfacility constructed within the SGHWR secondary containment for SGHWR wastes. TheRCBs will subsequently be transferred to Harwell for long-term storage in the Harwell ILWstore pending transfer to the GDF.301. There are also various items of operational ILW held within the SGHWR primarycontainment which it is proposed to process at the same time as decommissioning. Theseinclude seven historic waste containers stored in the under-core area containing a variety ofitems of high end LLW that are expected to be managed as CHILW or be categorised andmanaged as LLW following a suitable decay period. 10 stainless steel cans containing fuelrod ancillary items and pond waste currently stored within the reactor calandria andmortuary holes will be packaged with the reactor decommissioning ILW.7.1.2.3 Other ILWNuclear Material302. The following nuclear materials currently reside on the Winfrith site:• 57 tonnes natural uranium• 8 tonnes depleted uranium• 8kg thoria• 11 tonnes thorium.303. The natural and depleted uranium is contained in HHISO containers and stored in theTRS where it will continue to be monitored whilst options for its use are explored includingreturning it to the civil nuclear fuel cycle. The baseline strategy is to package and grout theuranium into RCBs at the end of SGHWR ILW processing and transfer it to Harwell for longtermstorage in the Harwell ILW store pending the availability of the GDF.RSRL IWS (Issue 5 – October 2012)83

NOT PROTECTIVELY MARKED304. The baseline strategy for thorium is for it to be transferred to the Harwell site for interimstorage pending packaging and disposal to the GDF. RSRL is actively pursuing anopportunity to return the thorium to the fuel cycle for re-use and therefore it will not beprocessed until later in the programme in order not to foreclose options.Miscellaneous ILW305. Miscellaneous ILW and redundant sources on the Winfrith site will also be processedthrough the SGHWR ILW Processing Plant and grouted into RCBs prior to transfer toHarwell for long-term storage in the Harwell ILW store pending disposal to the GDF.306. There are two areas associated with the management strategy for Winfrith ILW whichrequire further development:• The Robust Concrete Box needs to meet the requirements of RWMD and be approvedfor off-site transport.• The Harwell ILW Store needs to obtain necessary approval to receive Winfrith ILW.307. Figure 10 summaries the strategy for ILW at Winfrith:RSRL IWS (Issue 5 – October 2012)84

NOT PROTECTIVELY MARKEDDragonDecommissioningILWSGHWRDecommissioningILWPackage & groutinto RCBsTransportgrouted RCBs toHarwellMiscellaneous ILWstored in SGHWRILW Concrete LinedDrumsPackage &grout intoRCBsLong termstorage inHarwell ILWStorebaselineNatural andDepleted UraniumopportunityRecovery atSpringfields for re-useTransport toGeologicalDisposalFacilityThoriumbaselineTransfer to Harwellfor interim storageopportunitySell to third party forreturn to fuel cycleFigure 10: Winfrith ILW StrategyRSRL IWS (Issue 5 – October 2012)85

NOT PROTECTIVELY MARKED7.1.3 Low Level Waste308. RSRL is developing alternative routes for LLW in accordance with the actions listed inthe Joint Waste Management Plan. Of particular interest are off-site treatment routes forsegregated metals and combustible materials. RSRL is currently exploring the option ofsmelting metallic LLW and have identified some drums of suitable waste at Winfrith forwhich LLWR have quoted for treatment overseas. Transfer of this waste via the LLWRframework supplier contract is due to take place by the end of 2012. A route for disposal ofVLLW and LA-LLW at an off-site landfill have been in place for Harwell waste since March2012 and RSRL is working to establish this route for Winfrith wastes as well.309. In the site waste BPEO study the solid LLW was broken down into four categories: solidnon-combustible LLW, solid combustible LLW, solid VLLW and HV-VLLW wastes. Althoughthe current strategy is to send both combustible and non-combustible LLW to the LLWR,these wastes were differentiated in the study as it was envisage that there would bealternative options available in the future.310. RSRL has recently undertaken high-level strategic BAT reviews for metallic LLW,Winfrith LA-LLW / VLLW and “soft-solid” LLW (formerly this was referred to as “combustibleLLW” however as there are a number of treatment options available for this type ofsecondary waste the term “combustible” LLW is no longer appropriate). These reviewsincluded reassessment of the underlying assumptions and decisions taken at the time of theoriginal BPEO studies. A representative from LLWR Ltd attended each of the reviews.7.1.3.1 SGHWR Sludges311. SGHWR sludges are a mixture of organic resins used for the treatment of the reactorprimary coolant and sludge from primary circuit decontamination. Both bulk sludges andtank heels have been processed by encapsulation in cement inside 500-litre drums in theWETP. A sandy residue has been grouted into 40 litre grouted cans for disposal to theLLWR.312. These sludges are LLW but due to LLWR restrictions on the conditions for acceptance ofsome radionuclides they have in the past been managed as ILW. Following re-negotiationof LLWR’s position on the SGHWR sludges, RSRL has changed its baseline strategy forthese wastes to be disposal to the Low Level Waste Repository rather than the GDF. RSRLis working closely with LLWR to gain formal acceptance of the sludges however this isunlikely to be obtained until such time as LLWR have received an updated EnvironmentalPermit which aligns with their current Environmental Safety Case and it is possible for LLWRto assess the impact of the SGHWR sludges on their ability to receive waste from othercustomers.7.1.3.2 Solid Non-Combustible LLW313. Solid low level radioactive waste (LLW) is generated on the Winfrith site from routineoperations, the decommissioning of redundant nuclear facilities and the removal ofcontaminated land. The volumes involved vary depending on the type of operationundertaken and include change-room waste associated with the routine access/egress toactive areas, secondary wastes unavoidably generated during operations and materials thatbecome waste at the end of their useful life. The wastes will be in the form of wasteresidues, extract filters, scrap equipment and redundant plant.314. In developing its LLW management strategy Winfrith takes cognisance of the IndustryCode of Practice on Clearance and Exemption and where possible, segregates andRSRL IWS (Issue 5 – October 2012)86

NOT PROTECTIVELY MARKEDdecontaminates low level wastes to allow part to be treated as exempt (‘out of scope’)waste. Cutting is carried out on certain large items of solid LLW and surface removal ofcontaminated plant and equipment is also undertaken to remove the surface contaminationto enable disposal of the bulk of the item as exempt (‘out of scope’) waste (see 7.3.1 and7.3.2 for management of potentially exempt waste (PEW)). The Winfrith Abrasive CleaningMachine (WACM) may be used to decontaminate surface contaminated metallic waste onsite. Alternatively, metallic waste may be transferred off-site for further treatment under thecontact with LLWR.315. Where LLW items cannot be decontaminated, the current practice is to collect thewastes from the on-site facilities for supercompaction. Drums of similar LLW are alsoconsigned from Harwell for supercompaction. Following supercompaction, pucks are placedin containers that are approved for transport and disposal and then transferred to LLWR fordisposal. Bulk LLW is placed directly into approved containers at source for transfer toLLWR.316. The site waste BPEO Study identified two potential options for the management of thenon-combustible LLW generated at Winfrith: disposal to the LLWR (as per current practice)and on-site disposal. However only disposal to the LLWR was identified as being practicallyfeasible for the more radioactive low level wastes. The end state for the Winfrith site is a delicensedsite and it was considered that on-site disposal of LLW would not be compatiblewith the ONR de-licensing criteria. This position excludes metallic wastes that areaddressed by a separate BAT Assessment which concluded that on-site treatment wasBAT, closely followed by off-site treatment.317. Although disposal to the LLWR is a well established and existing disposal route, Winfrithrecognises that the future availability of the facility is a risk however it is considered that thisis a wider industry issue that will require higher level decision making by the NDA.7.1.3.3 Soft Solid LLW318. Soft solid LLW, such as personally protective equipment, clothing, wood etc. may arisefrom any activities within the radiation and contamination controlled areas on the site.Where it is practicable to do so, soft solid LLW is differentiated from other LLW and thesewaste are segregated at source. RSRL is developing arrangements with LLWR to establisha combustible waste disposal service in order that segregated wastes may be transferred toan off-site treatment facility. Arrangements for the segregation of combustible soft solidwastes are still developing, but RSRL is committed to doing so in recognition thatincineration services are available through the contract with LLWR and incineration hasbeen identified as BAT at strategic level for soft solid wastes.7.1.3.4 Solid HV-VLLW319. Significant quantities of VLLW will be produced as a result of the decommissioningactivities at the Winfrith site. An Authorisation is in place at Winfrith for the disposal ofVLLW to local landfill however due to the annual limits associated with this route, along withnuclear liability insurance issues, RSRL is currently considering alternative routes such asthat utilised by the Harwell site.320. In 2010 the EA issued a variation to the Winfrith Authorisation thereby enabling thedisposal of high volume VLLW via the service offered by LLWR. In 2011, followingnegotiations between RSRL and EA, the EA amended the CEAR (Compilation of EARequirements, Approvals and Specifications) to set a volume limit for HV-VLLW transferredvia LLWR.RSRL IWS (Issue 5 – October 2012)87

NOT PROTECTIVELY MARKED321. A forward programme has been prepared for utilisation of the route used by Harwell andit is envisaged that the first shipment of waste from Winfrith will take place by January 2013.Whilst RSRL already has an EA permit to dispose of HV-VLLW (material with an activity of4Bq/g) to the landfill. An application for arevision to the existing permit has been drafted and is due to be submitted in the early partof 2013.7.1.3.5 LLW Organic Sludges322. Organic sludge arisings comprise mainly of sewage sludges from the Active LiquidEffluent System (ALES), which are used to treat active foul water arisings prior to seadischarge. These wastes are currently segregated, dewatered and packaged prior toincineration at an off-site facility. There is an ongoing generation of these wastes.323. The relatively small volumes of active sludge wastes from the ALES plant means thatthere is currently no practicable viable alternative to the existing strategy of incineration.Given the close geographical location of the currently utilised incineration facility and thehigh levels of abatement fitted to the incinerator, use of an on-site incinerator (permanent ormobile plant) as an alternative would offer no benefits.324. Figure 11 summaries the strategy for LLW at Winfrith:RSRL IWS (Issue 5 – October 2012)88

NOT PROTECTIVELY MARKEDEncapsulatedSGHWR LLWSludgesStorage in TreatedRadwaste StoreTransfer to LLWRCompactable LLWSolid LLWMetallic LLWvia SolidWaste OpsTransfer fortreatmentCombustible LLWsecondary wastes andcompacted LLWNon-Compactable/Bulk LLWvia Solid Waste OpsTransfer toLLWROrganic LiquidLLWOff-site incinerationExempt (out of scope)waste or recycledexemptBulk SodiumRepacking ofsodium intoappropriatecontainersempty pkgsDisposal of emptycontainers followingrepacking of sodiumrepackaged sodiumOff-siteIncinerationLA-LLW andHV-VLLW fromdecommissioningand landremediationStorage on-sitepending development of routeOff-site Landfilldisposal facilityFigure 11: Winfrith LLW StrategyRSRL IWS (Issue 5 – October 2012)89

NOT PROTECTIVELY MARKED7.1.4 Other Solid Radioactive Waste7.1.4.1 Sodium and Mercury325. Approximately 25 tonnes of bulk sodium metal, in a variety of sealed packages, rangingfrom a few kilos on mass to several tonnes, has been stored on the Dragon ReactorComplex. Following the completion of a BAT assessment (ref. A1141/RPT/0006) during2011, the methodology for processing this waste has been finalised. The packages arebeing opened in a dry, dehumidified atmosphere where the sodium is retrieved in 10kgaliquots and placed in double polyethylene bags and vacuum packed. These are placed intolarger bags which are nitrogen purged and in turn placed into Intermediate Bulk Containers(IBCs). Sampling has shown the sodium to be below exempt (out of scope) levels howeversome of the packaging is classed as radioactive waste. The sodium is being transferred offsitefor incineration.326. Small quantities of mercury are expected to arise during decommissioning operations.Items will be monitored and sent to a specialist contractor for disposal at a hazardous landfillafter first consolidation with any similar materials from Harwell. In the site waste BPEOstudy, re-use was identified as the preferred option for mercury. However it would benecessary to secure a third party willing to accept the material for re-use hence the fallbackoption of disposal at a hazardous landfill will continue. Contaminated mercury is identifiedas an orphan waste by LLWR and development of a route for this waste is currently anaction under the National Waste Programme.7.1.4.2 RSRL Tenanted Liability Wastes327. There are some waste items on the Winfrith site which are an agreed RSRL liability butare currently held or operated by a site tenant. These include some tritium wastecomprising 15 neutron generators, which will be de-tritiated and the residue disposed of viaALES. Solid wastes will be sent to the LLWR as LLW.328. Some items of SAFER equipment are still in use and will not be disposed of until the endof the current lease agreement. It is proposed that the majority of the work will be carriedout by the tenant using their existing plant and equipment. The proposed processingmethodology and disposal routes are both well established and currently in use.7.2 Radioactive Discharges7.2.1 Liquid Discharges7.2.1.1 Liquid LLW Discharges329. Radioactive liquid waste generated at Winfrith includes:• Liquid foul effluent• Active process effluent• Tritiated groundwater• LLW organic liquids330. The treatment arrangements for these wastes are described below. There are interfacesbetween the management strategies for the liquid foul and active process effluent, howeverthe tritiated groundwater and the LLW organic liquids are managed independently of theother liquid waste streams.RSRL IWS (Issue 5 – October 2012)90

NOT PROTECTIVELY MARKED7.2.1.2 Liquid Foul Effluent331. The notionally active (historically) foul effluent is processed through the site sewagetreatment plant which includes settling tanks and bacteria beds to reduce suspended solidsand organic content respectively, before being transferred to the Active Liquid EffluentSystem (ALES) for discharge into the English Channel along with the active effluent throughthe inner pipeline.332. The site waste BPEO Study considered alternative options for the management of theliquid foul effluent including evaporation, filtration and discharge to an off-site commercialplant. However, with the volume of the foul effluent and suspended solids load alreadybeing minimised through application of BPM, it was considered that the current practice ofprior treatment followed by direct discharge via the sea pipeline is the BPEO for thefollowing reasons:• The low specific activity characteristics of the effluent and hence consequential dosesfrom discharges are negligible;• Minimal operator intervention required with current practice and hence minimal on-siteradiological and safety risks;• Environmental impacts are minimal as negligible secondary wastes would beproduced, resource use would be negligible and there would be no requirement fornew plant; this accords with the principles of the National Radioactive DischargeStrategy333. Although direct discharge is the current preferred strategy it will be kept under reviewwith regard to changing characteristics of the effluent.7.2.1.3 Active Process Effluent334. The active process effluent waste stream includes the radiologically contaminatedground water from beneath the now demolished Active Handling Complex. This containsvery little activity and most of the problem is with suspended solids.335. The primary radionuclide in the active effluent with respect to dose to the critical group iscaesium-137, whilst in terms of total activity is tritium. No abatement plant currently exists tocontrol the activity of discharges from site. BPM is applied at facility level to ensure that theactivity is controlled at source, rather than relying on treating the effluent once it has beencollected from around the site. The active process effluents are collected in holding tanksand, after treatment through the ALES (analysis of effluent samples and pH correction oftank contents), are discharged to sea under a permit and consents granted by theEnvironment Agency (EA).336. The site waste BPEO Study looked at alternative management options for the activeprocess effluent including ion exchange and filtration. However the high volume of effluentpassing through the ALES system with a relatively high natural ionic content would make ionexchange impractical because of the quantities of resin that would be required to be usedand given the very low radioactive particulate content of the process effluent the detrimentsin terms of having to manage solid wastes from implementing filtration would significantlyoutweigh any benefits.337. However, in order for RSRL to meet it’s obligation to use best available techniques tominimise entrained solids in aqueous waste prior to discharge to the environment aprogramme of work to improve the ALES system was undertaken during 2011. Theinstallation of a lamella inclined plate clarifier unit designed to use gravity settling to clarifyRSRL IWS (Issue 5 – October 2012)91

NOT PROTECTIVELY MARKEDliquid effluent took place. In addition, a high efficiency filtration unit was installed to filter andremove most of the finer entrained solids remaining after clarification, prior to discharge tothe sea.338. Therefore the current practice of prior treatment followed by direct discharge via the seapipeline continues to be the baseline strategy as it is for liquid foul effluent.7.2.1.4 Tritiated Groundwater339. Tritium contamination at very low concentrations is present in the groundwater on partsof the Winfrith site. During demolition operations across the Winfrith site, some operationswill involve excavation below ground level. These areas may become flooded withgroundwater, creating difficult operating and safety environments. These problemsassociated with groundwater can be overcome by dewatering. It is the management ofthese dewatering effluent arisings that are considered under this waste stream. Themanagement of the radiologically contaminated water extracted from under the nowdecommissioned Active Handling Complex is considered under the Active Liquid ProcessEffluent as the radioactivity is caesium and strontium rather than tritium.340. The site waste BPEO Study considered three options for the management of the tritiatedgroundwater: discharge to the River Win/Frome; discharge to sea using ALES; and pumpingback into the ground. In spite of the obvious environmental benefits of discharging thetritiated ground water to sea via the ALES, the risks to plant and operators from having todeal with large volumes of water above the equipment’s design capacity make this animpracticable option. Given the very low levels of tritium within the ground water, dischargeof the effluent to the River Win/Frome offers a robust management strategy, subject tomaintenance of strict controls with respect to ensuring the removal of silt prior to dischargeand controls of effluent flow rates into the river tributary. The management option ofpumping the water back into the ground offers a potential future strategy/opportunity if therewere problems with discharging the ground water to the river, however it would require moredetailed investigation before it could be practically implemented.341. The current reference strategy for the tritiated groundwater is therefore to discharge it tothe River Win/Frome. However as stated above, this will be subject to maintenance of strictcontrols to ensure discharges are kept below the levels specified in the Permit issued by theEnvironment Agency .7.2.1.5 LLW Organic Liquids342. Active waste oils and organic solvents arise in a number of facilities as a result of normaloperations and during maintenance. There are also accumulated hydraulic and lubricantwaste oils and organics solvents. The oils and organic solvents are currently storedawaiting disposal; some of these have already been consigned to an off-site incinerationservice.343. A disposal route was established in 2003 for the off-site incineration of organic liquid andcertain solid LLW. RSRL is utilising this route for disposal of contaminated oils and driedactive sewage sludge. In the past Winfrith has consigned Zinc Bromide LLW as well as alarge volume of historic active sewage drums for incineration. The use of the currentlyutilised incinerator is a key waste route for Winfrith’s organic LLW disposal strategy andWinfrith will therefore keep up-to-date with its availability.344. Several alternative management options for LLW organic liquids were considered duringthe site waste BPEO Study including high temperature combustion, chemical oxidation,disposal as a solid, storage and decay, evaporation and on-site incineration. It was agreedRSRL IWS (Issue 5 – October 2012)92

NOT PROTECTIVELY MARKEDthat high temperature combustion technology and chemical oxidation techniques added nobenefits over incineration for this waste stream. Disposal as a solid, storage and decay, andevaporation were also rejected for various regulatory and practicability reasons. For certainwastes the cost of incineration is high, and therefore RSRL is currently looking intoalternative treatment options for oils and solvents. Any change in strategy for this type ofwaste will be documented in future revisions of the IWS.345. The BPEO study did explore the feasibility of an on-site incineration facility however thepreferred option was identified to be off-site incineration. The use of this route is via theLLWR contract.346. Figure 12 summarises the strategy for Organic and Aqueous Liquids at Winfrith:RSRL IWS (Issue 5 – October 2012)93

NOT PROTECTIVELY MARKEDRadioactiveLiquid EffluentLiquid effluentmonitoring atALESInner section ofSea Pipeline out to seaNon-activeeffluentDischarge to SeaLiquid effluentmonitoring atALESOuter section ofSea Pipeline near coastTritiated surfacewater fromSGHWRliquidLiquid fouleffluentProcess atsewage plantsolidOrganic Liquid(Oils andSolvents)Off-siteIncinerationFigure 12: Winfrith Liquid Waste StrategyRSRL IWS (Issue 5 – October 2012)94

NOT PROTECTIVELY MARKED7.2.2 Gaseous Discharges347. The gaseous discharges on the Winfrith site fall under two categories:• Gaseous radioactive emissions• Particulate airborne emissions7.2.2.1 Gaseous Radioactive Emissions348. The main source of gaseous aerial emissions is tritium from the Steam GeneratingHeavy Water Reactor (SGHWR) and C-14 from the Winfrith EAST Treatment Plant.Discharges from Dragon are negligible (

NOT PROTECTIVELY MARKEDwaste are to go to specific landfills. Thus the non-radioactive waste produced at Winfrithhas been broken down into these three categories.7.3.1 Hazardous Non-Radioactive Wastes356. The solid hazardous waste produced at Winfrith mainly comprises of lead and asbestos.357. Bulk lead is used extensively for shielding and where possible the strategy is to removeany radioactivity as lead shavings and consign them to the LLWR. The remaining clean orexempt (‘out of scope’) bulk lead is recycled by selling directly to the marketplace.358. Removal of accessible asbestos will be undertaken by a registered asbestos contractorwho will be made available to undertake such duties, at short notice, throughout thedecommissioning operations. The asbestos is all within the primary containment soestimates will be updated when work starts there, in order to comply with ALARPprocedures.7.3.2 Non-Hazardous Non-Radioactive Wastes359. The non-hazardous waste is expected to comprise mainly of industrial wastes such assteel and commercial wastes such as sensitive paper wastes and general office wastes.These wastes are re-used and/or recycled where possible and where this is not possiblethey are sent off-site for disposal at landfill.7.3.3 Inert Non-Radioactive Wastes360. The inert waste is expected to comprise mainly of industrial wastes such as concreteand masonry. This waste is monitored to ensure that it meets with the criteria for exempt(‘out of scope’) waste.361. The majority of the inert waste is consigned for recycling prior to re-use; however, anyclean rubble is sent to the Winfrith Rubble Compound which has been created to ensureRSRL maximises the use of on-site resources in restoring the site. This adopts theprinciples of sustainable development and the proximity principle. Materials accumulated inthe rubble store are used for land remediation following the decommissioning and demolitionactivities.362. Figure 13 summarises the strategy for non-radioactive waste at Winfrith:RSRL IWS (Issue 5 – October 2012)96

NOT PROTECTIVELY MARKEDRecyclablehazardous wasteClean, monitor andrecycleMercuryDisposal routeunder developmentby LLWRHAZARDOUSWASTEOils and solventsOff-site incinerationAsbestosSend to hazardouslandfillLLWTransfer toLLWRBulk Sodiumempty pkgsDisposal of emptycontainers followingrepacking of sodiumVLLWProcess asmetal VLLWRepacking of sodiuminto appropriatecontainersrepackaged sodiumexemptLandfill orrecycleOff-site IncinerationReusable nonhazardouswasteMonitor and re-useNON-HAZARDOUSWASTERecyclable nonhazardouswasteMonitor and recycleNon-hazardouswasteConsign to inert ornon-hazardouslandfillINERT WASTEReusable concrete,building rubble andsoilFigure 13: Winfrith Non-radioactive Waste StrategyReuse on siteas infillSurplus sent toinert landfillRSRL IWS (Issue 5 – October 2012)97

NOT PROTECTIVELY MARKED7.3.4 Non-Radioactive Discharges7.3.4.1 Liquid Discharges363. The non-radioactive operational liquids at Winfrith mainly comprise oils, greases andorganic solvents.364. Non radioactive waste oil and grease arisings are typically recycled but if they areextremely degraded and regarded as non-recoverable, they are consigned off-site forincineration.365. The limit for non-radioactive zinc in groundwater has been breached; the zinc issuspected to have arisen from material brought onto site to infill voids. Additional samplingand analysis will be carried out to monitor zinc levels (see change proposal RSRL/09/015).EA have agreed verbally that, as is the case for TCE (Tricholorethylene), the contaminationwill be deemed to be remediated through “managed natural attenuation” and will not requirephysical remediation.366. There are no other significant aqueous liquid discharges. Where present, aqueousliquids are processed through the site sewage treatment plant, and then discharged, via theALES, to sea.367. Surface water (i.e. rain) arising on the site is channelled via flumes into local rivers.7.3.4.2 Gaseous Discharges368. There are no significant non-radioactive gaseous discharges produced on the Winfrithsite. Any gases generated are discharged in a controlled manner to the atmosphere.7.4 Waste Disposal and Transfer Routes369. The current authorised waste disposal and transfer routes from the site are shown in thetable below.Current Waste Disposal and Authorised Transfer RoutesRadioactive Waste TypeGaseous WasteAqueous WasteOrganic WasteAuthorised Transfer/Disposal RouteDischarge to the environmentDischarge to seaTransfer off-site for incineration at FawleyTransfer to HarwellSolid Waste (includingsources)Transfer to the LLWR for disposal or subsequenttransfer elsewhereTransfer to the Sellafield site operator for finaldisposal at LLWR or for subsequent transferelsewhereTransfer to metals recycling facility at LillyhallRSRL IWS (Issue 5 – October 2012)98

NOT PROTECTIVELY MARKEDNon-Radioactive WasteTypeOrganic Liquid WasteTransfer/Disposal RouteTransfer off-site for incinerationSolid WasteOrganic Solid WasteLandfill siteTransfer off-site for incineration at FawleyHazardous WasteLandfill or transfer off-site for incineration370. It is expected that, subject to continued contractual agreements, the low level solidwaste produced on the Winfrith site will continue to be transferred to the LLWR for disposaland that a Geological Disposal Facility (GDF) will be available from 2040 to accept Winfrithsolid ILW stored in the Harwell ILW store.371. Winfrith has a permit for the consignment of its organic wastes and some hazardouswastes to the incinerator at Fawley under the contract with LLWR. Agreements are in placewith the Harwell site for acceptance of a number of ILW sources from Winfrith. Thesetransfers are included in the Harwell part of the current LTP baseline and have a GREENtraffic light status. The status of all inter-site transfers involving Winfrith was given inSection 4.5.3. There are some further ILW sources for which the baseline strategy is thatthey will be transferred to Harwell for processing and disposal. There are currently no plansto transfer Winfrith waste to any other NDA sites.372. The logistics of movements of wastes on and off-site are fundamental to the sitestrategy. Therefore Winfrith develops flask and transport strategies for its wastes. Indeveloping a strategy for a particular waste stream, the site considers the following issues:• the key facilities through which the waste stream is routed• the transport method• the shipment route including the potential safety and environmental impact on localcommunities• the transport package• estimated journey times and when the transfer will take place• loading/unloading requirements and any restrictions• timings• the actions that will need to be undertaken prior to transport e.g. obtaining the flasks,flask approvals, route approvals, hiring lifting equipment (crane/fork-lift truck)373. Flask and transport strategies for individual waste streams are integrated with eachother. For example, in developing reference strategies, RSRL considers whether materialswith similar properties at different sites can be managed together, potentially reducing therequirement for management in terms of cost and resources as well as for storage andprocessing facilities. The strategies are continually reviewed to ensure that necessaryfacilities and transport capacity is available on the appropriate timescale, to identify anyareas where there are ‘gaps’ in provisions or strategies and to look at the impact ofchanging the strategies.RSRL IWS (Issue 5 – October 2012)99

NOT PROTECTIVELY MARKED8 AREAS REQUIRING FURTHER DEVELOPMENT & ACTION PLAN374. Key areas of the IWS requiring further development are tabulated below. They includedevelopments identified in the previous issue of the IWS and an update of status.Development RequirementThe strategy for:(1) Natural Uranium and(2) Depleted Uranium hasnot been finalised.OngoingThe final strategy fordecommissioning of theRiver Thames dischargepipelineHarwellAction Plan and Status(1) Negotiations with SFL started in 2006 to agree a transferof the uranium to Springfield however it has not been possibleto achieve a handshake for the transfer of this waste. Thestrategy continues to be long-term storage on the Harwell siteuntil the GDF is available. Before consignment to the GDFthe material will be repackaged and grouted in 500-litredrums. Transfer to Springfield continues to be identified asan opportunity.(2) Negotiations are in progress with an external contractor todevelop a route for depleted uranium.This work has been considered as an opportunity in thestrategy review.A preliminary option study was carried out during 2012.Technical specifications will be developed and a test sectionof the pipeline removed for characterisation to inform on thefinal strategy.OngoingHarwell Optimised PlanOngoingProvision of a new ILWstore at HarwellNEWProvision of transportpackages for nuclearmaterials transferNEWRSRL have reviewed the options for optimising thedecommissioning programme at Harwell. The findings havebeen presented to the NDA and been reviewed by the RSRLexecutive committee. Some of the relevant changes havebeen made to the LTP.The conceptual design of a new ILW store has beencompleted and the planning application drafted. The storewill need to accommodate ILW packages arising fromdecommissioning of both the Harwell and Winfrith sites.RSRL continues to have dialogue with local councils andstakeholders.A number of Type B transport packages are required in orderto transfer nuclear materials from Harwell to Sellafield. Thesepackages need to be approved for use by ONR (RMT).Discussions with ONR (RMT) will continue.RSRL IWS (Issue 5 – October 2012)100

NOT PROTECTIVELY MARKEDDevelopment RequirementTransfer SGHWR sludgesto LLWRNEWDevelop the use of RobustConcrete BoxesNEWWinfrith Optimised PlanDevelopedThe final strategy fordecommissioning of theSea Disposal SystemDevelopedWinfrithAction Plan and StatusFollowing a RSRL review of the isotopic content of this waste,discussions are underway to gain formal acceptance for themto be disposed of via LLWR.The use of Robust Concrete Boxes for the packaging,transport and disposal of ILW will need to comply with RWMDand ONR (Transport) requirements. Discussions areunderway.RSRL submitted a programme level business case outliningoptions for optimising the decommissioning programme atWinfrith. NDA have considered the options and changeshave been made to the LTP resulting in a RSRL OptimisedProgramme.As part of the Winfrith Optimised Plan the strategy fordecommissioning of the Sea Discharge Pipeline has beenreviewed and changed from grouting and excavation todecontamination and leaving the pipes in-situ.375. Opportunities for improving waste management for consideration by NDA include:OpportunityA national strategy fornuclear materials such asuranium.OngoingDevelop alternatives forthe treatment or disposalof LLWNEWRSRLJustificationWinfrith natural and depleted uranium will be stored in theTRS and Harwell natural and depleted uranium will be storedin the SWC whilst options for its re-use are explored. If it isdeclared as a waste it will be packaged in RCBs and sent tothe Harwell ILW store for long-term storage pending transferto the GDF. The current strategy for low enriched uranium isto transfer it to Sellafield as part of the NM project. Howeverthere is an opportunity to transfer the low enriched uranium,natural uranium and depleted uranium off-site for recovery atSpringfields or via a commercial contractor. The volumes ofuranium at Winfrith Harwell are small compared to the rest ofthe nuclear industry. There is an opportunity for NDA toformulate a nationwide strategy for uranic residues.In order to reduce the volume of LLW disposed of at LLWRRSRL is developing alternative routes in accordance with theactions listed in the Joint Waste Management Plan. Ofparticular interest are off-site treatment routes for segregatedmetals and combustible materials. A route is in place for thedisposal of VLLW and LA-LLW from Harwell and RSRL isworking to establish this route for Winfrith wastes as well.RSRL IWS (Issue 5 – October 2012)101

NOT PROTECTIVELY MARKEDOpportunityThe processing of reactorgraphite for disposal.OngoingDesign of a new HarwellILW StoreNEWHarwellJustificationThe current strategy for reactor graphite is to package it intoRCBs for storage then disposal in a deep waste repository(GDF). The graphite at Harwell is small in volume whencompared to the rest of the nuclear industry and it might bebeneficial for NDA to consider a nationwide strategy forgraphite.There is an opportunity to collaborate with Magnox on thedesign of the new ILW store at Harwell. This could result insavings in feasibility costs and taking advantage of lessonslearned.OpportunitySale of ThoriumNEWWinfrithJustificationWork will be undertaken to identify opportunities to returnthorium to the fuel cycle.RSRL IWS (Issue 5 – October 2012)102

NOT PROTECTIVELY MARKED376. Further work identified to manage assumptions, uncertainties and risks are tabulated inthe action plan below. Development work completed or deleted during the last year is alsodetailed.Action Plan Date Responsibility forImplementationThe IWS will be reviewed,Annually in RSRLupdated and issued annually as Marchpart of the LTP planning cycle. (next in 2013)The review is planned to becompleted to support the LTPsubmission in March each year.Review andupdate ofRSRL’s IWS.Design, approval& commissioningof a new ILWstore at HarwellTransportpackages fornuclear materialstransfersTransfer SGHWRsludges to LLWRDevelopment ofsegregatedwaste routes forLLWDevelopment work to obtainsuitable planning permission,confirm design, build andcommission a new ILW store atHarwellDevelopment work to obtain ONR(RMT) approval of Type Bpackages for the transport ofnuclear materials to SellafieldDevelopment work to obtainapproval to transfer SGHWRsludges to LLWRDevelopment of routes forcombustible waste, metallic wasteand Winfrith HV-VLLW / LA-LLWin line with the RSRL and LLWRJoint Waste Management Plan.2017 RSRL2013 RSRL2015 RSRL2013 RSRLStrategy forNatural andDepletedUraniumStrategy forHarwellDischargePipelineStrategy forWinfrith SeaDisposal SystemHarwelloptimiseddecommissioningprogrammeWinfrithoptimiseddecommissioningprogrammeDevelopment work to optimise thestrategy for natural and depleteduraniumDevelopment work to optimise thestrategy for the Harwell DischargePipelineDevelopment work to optimise thestrategy for the Sea DisposalSystemDevelopment work to optimise thestrategy for HarwelldecommissioningDevelopment work to optimise thestrategy for Winfrithdecommissioning2013 RSRL2014 RSRL (Harwell)DEVELOPED RSRL (Winfrith)DEVELOPED RSRL (Harwell)DEVELOPED RSRL (Winfrith)377. The RSRL Waste Strategy Group (RWSG) will also monitor the progress ofimplementation of the waste strategy but any changes in strategy will be subject tochange control and sanction and validation processes.RSRL IWS (Issue 5 – October 2012)103

NOT PROTECTIVELY MARKED9 CONCLUSIONS378. The RSRL Integrated Waste Strategy document summarises the strategy for managingwastes on the Harwell and Winfrith sites. It provides information to underpin the wastestrategy in the RSRL lifetime plan. The IWS has been developed through the use of BPEOmethodology including the involvement of stakeholders although this process is beingsuperseded by BAT assessments with the introduction of the Environmental PermittingRegulations 2010. Integrated waste strategies have been developed for each of the maingroups of waste in stock or expected to arise from decommissioning and are detailed in thisdocument.379. The Integrated Waste Strategy for the Harwell and Winfrith sites is to package all ILWinto final disposal packages and decommission redundant facilities by 2032 and 2024respectively. The strategies are guided by the waste hierarchy and waste minimisation bybest practicable means. Once waste has arisen or when it already exists, the strategy is tosegregate the waste into the lowest hazard or radioactivity category and to make full use ofthe available disposal routes. When this is not possible, such as for ILW, the strategy is toeither make the waste passively safe for long term storage or to transfer it to another NDAsite for processing and storage pending final disposal.380. Features of the RSRL strategy include:• the processing and storage of legacy ILW on the Harwell site,• the transfer of Harwell legacy Nuclear Materials to Sellafield• the long-term storage of uranium on the Harwell site,• the provision of a new ILW store at Harwell for long-term storage ofdecommissioning ILW• the provision of a deep waste repository (GDF) for packaged ILW and• the continued availability of disposal routes for LLW, LA-LLW and HV-VLLW381. Improvements and changes to the IWS since the last issue include:• The change in strategy from the use of 2m boxes for Winfrith decommissioning ILW(all projects) and Harwell reactors decommissioning ILW to packing and grouting intoRobust Concrete Boxes• The transfer of Robust Concrete Boxes containing grouted Winfrith ILW to theproposed Harwell ILW for interim storage pending disposal to the GDF• The deletion of scope, schedule and costs for design, build and commissioning of anew ILW store at Winfrith• The transfer of Winfrith thorium metal to Harwell for interim storage pendingpackaging and disposal to the GDF. An opportunity to return it to the fuel cycle isbeing pursued• The transfer of encapsulated SGHWR sludges, currently stored in the TRS atWinfrith, to the Low Level Waste Repository rather than the GDF• The re-categorisation of some Harwell LETP Low Level legacy sludges from LLW toILW. These sludges have been encapsulated and will remain in interim storage inthe Solid Waste Complex pending final disposal to the GDF.RSRL IWS (Issue 5 – October 2012)104

NOT PROTECTIVELY MARKED382. In order for the waste strategy to be implemented the following key issues must beresolved:• the availability of additional storage at Harwell for ILW from Winfrith and Harwellsites• the availability of approved transport containers for the transfer of nuclear materialsfrom the Harwell site to Sellafield and for the transfer of ILW from Winfrith to Harwell• the availability of the Geological Disposal Facility in the required timescale.• obtaining formal acceptance of the SGHWR sludges from LLWR.RSRL IWS (Issue 5 – October 2012)105

NOT PROTECTIVELY MARKEDANNEX LISTAnnex 1:Annex 2:Annex 3:Annex 4:Waste Data Tables - RESTRICTEDAuthorised Radioactive Waste Disposal Types and Disposal RoutesMain Regulatory Principles and Related Drivers and Constraints thataffect RSRL’s waste management strategyGlossary and AcronymsRSRL IWS (Issue 5 – October 2012)106

NOT PROTECTIVELY MARKEDANNEX 1: WASTE DATA TABLES (RESTRICTED)Data Tables available separately.RSRL IWS (Issue 5 – October 2012)107

NOT PROTECTIVELY MARKEDANNEX 2: AUTHORISED RADIOACTIVE WASTE TYPES ANDDISPOSAL ROUTESSchedule 3 of Environmental Permit Number EPR/KP3593SH/V001for Research Sites Restoration Ltd (Harwell Oxford Science Campus)Radioactive Waste TypeGaseous WasteAqueous WasteHV-VLLWHV-VLLWLLWLLWMetallic LLWMetallic LLWCombustible LLW wasteand combustible liquidwasteCombustible LLW wasteand combustible liquidwasteILWRadioactive Waste asdefined in the TransfrontierShipment of RadioactiveWaste Regulations 1993or the TransfrontierShipment of RadioactiveWaste and Spent FuelRegulations 2008Transfer/Disposal RouteDischarge to the environmentDischarge to public sewer, Lydebank Brook and RiverThamesThe holder of an environmental permit for the receiptand disposal of HV-VLLW (for subsequent treatmentand/or transfer for disposal)The holder of an environmental permit for the receiptand disposal of HV-VLLW by on-site disposalThe holder of an environmental permit for the receiptand disposal of LLW (for subsequent treatment and/ortransfer for disposal)The holder of an environmental permit for the receiptand disposal of LLW by on-site disposalThe holder of an environmental permit for the receiptand disposal of LLW (for subsequent treatment and/ortransfer for disposal)The holder of an environmental permit for the receiptand disposal of LLW by on-site disposalThe holder of an environmental permit for the receiptand disposal of LLW (for subsequent treatment and/ortransfer for disposal)The holder of an environmental permit for the receiptand disposal of LLW by on-site disposalAny nuclear operator holding an environmental permitfor the receipt of radioactive wasteTransfer in accordance with the conditions of anauthorisation granted under the Transfrontier Shipmentof Radioactive Waste Regulations 1993 or theTransfrontier Shipment of Radioactive Waste and SpentFuel 2008RSRL IWS (Issue 5 – October 2012)108

NOT PROTECTIVELY MARKEDSchedule 2 of 2009 RSA Authorisation (Ref BW2536/CC2666)for Research Sites Restoration Ltd (Winfrith site)Radioactive Waste TypeGaseous WasteAqueous WasteSolid WasteDisposal RouteDischarge to the environmentDischarge to the environmentTransfer to the Sellafield Site Operator at Sellafield forthe purpose of final disposal at the LLWR at Drigg orsubsequent transfer elsewhereTransfer to the LLWR Site Operator at Drigg for thepurpose of final disposal at the site or subsequenttransfer elsewhereTransfer to the person authorised under section 13 ofthe Act to dispose of solid waste by incineration on orfrom the premises at:Charleston Road, Hardley, Hythe, Southampton,Hampshire, SO45 3ZATransfer to the operator of the SWC and AHF facilities atthe Harwell nuclear site for the purpose of storageTransfer to the person operating Complexes B4 and A5(with the exception of Building A512) on the Winfrith sitefor the purpose of treatmentVery low level waste disposal to landfillOrganic Liquid WasteTransfer to the person authorised under section 13 ofthe Act to dispose of solid waste by incineration on orfrom the premises at:Charleston Road, Hardley, Hythe, Southampton,Hampshire, SO45 3ZARadioactive Waste asdefined in the TransfrontierShipment of RadioactiveWaste Regulations 1993or the TransfrontierShipment of RadioactiveWaste and Spent FuelRegulations 2008Transfer in accordance with the conditions of anauthorisation granted under the Transfrontier Shipmentof Radioactive Waste Regulations 1993 or theTransfrontier Shipment of Radioactive Waste and SpentFuel 2008RSRL IWS (Issue 5 – October 2012)109

NOT PROTECTIVELY MARKEDANNEX 3: REGULATORY CONSTRAINTS AND DEPENDENCIESThe external policy and regulatory framework is complex with regulations / legislation coveringradioactive waste, liabilities management, nuclear facility decommissioning, radioactivedischarges, general waste strategies, sustainable development, health and safety, and security.The main policy and regulatory framework providing drivers and constraints for the RSRL wastemanagement strategies are given here.RegulationThere are various regulators who regulate the RSRL sites in accordance with legalrequirements and ensure that Government Policy is implemented. These include:• The Office for Nuclear Regulation (ONR), created on 1 April 2011 following the merger ofthe Health and Safety Executive's Nuclear Directorate (the Nuclear InstallationsInspectorate, the Office for Civil Nuclear Security, the UK Safeguards Office, and theDepartment for Transport's (DfT) Radioactive Materials Transport Team).• The local authority, which is responsible for planning issues• Euratom, which ensures that special nuclear material obligations are met by the site;The production of the IWS is a contractual and regulatory requirement for NDA sites, bothgenerally under the umbrella of the requirement for sites to undertake strategic planning for allwastes and specifically under the ONR HSE Safety Assessment Principles (RW 1).Legislative FrameworkThe main legislation concerning the safety of nuclear installations is the Health and Safety atWork etc. Act 1974 (HSWA74), the associated relevant statutory provisions of the NuclearInstallations Act 1965 (as amended) (NIA65) and the Ionising Radiations Regulations 1999(IRR99). These Regulations set the maximum permissible dose to a member of the public at1mSv/year and to a radiation worker at 20mSv/year, and also requires the dose to be as low asreasonably practicable (ALARP). These limits require processes with high activity materials tobe undertaken using remote handling techniques.The main legislation for the regulation of radioactive materials and radioactive waste is NIA65and the EPR2010.Non-radioactive (‘controlled’) wastes on and off nuclear licensed sites will be managed anddisposed of in accordance with the Environmental Protection (Duty of Care) Regulations 1991,Hazardous Waste Regulations 2005 and Environmental Permitting (England and Wales)Regulations 2010 (EPR2010) (and as amended). Storage, recovery or disposal will dependupon the waste management option(s) selected and an environmental permit issued underEPR2010 may apply to hazardous and non-hazardous wastes depending on the type of activity(and its capacity) to which the wastes are put.The primary legislation for contaminated land is the Environment Act 1995, the EnvironmentalProtection Act 1990 (EPA1990) and NIA65.EPR2010 Permits [ 16 ]Permits are required for discharge of gaseous and liquid wastes to the environment and for thedisposal of solid wastes. Conditions imposed in such permits require holders to use BAT to16 With the implementation of EPR, documents originally issued as “Authorisations” are now to be referredto as “Permits”. This document is consistent with this change.RSRL IWS (Issue 5 – October 2012)110

NOT PROTECTIVELY MARKEDminimise discharges and to ensure that discharges of radionuclides are kept within prescribedlimits. Regulatory control for discharges from nuclear licensed sites is exercised by theEnvironment Agency in England and Wales, who have suggested a number of principles forenvironmental protection. EPR2010 permits and their variation need to be considered duringthe development of waste strategies at RSRL’s sites.Site Licence ConditionsThe sites are licensed under the NIA65 and operate in accordance with the 36 Nuclear SiteLicence conditions attached to this licence, which conditions relating to the management andaccumulation of radioactive waste. Those of particular relevance to the management ofradioactive waste are 4-6, 11, 14, 15, 17, 23, 25, 26, 28 and 32-35. These, inter alia, requireoperations to be supported by safety cases and records to be maintained of the amount andlocation of all radioactive materials. ONR has statutory powers under NIA65 for the regulationof the safe management of radioactive material, including radioactive waste, on nuclear sites,prior to disposal, taking into account the views of the environment agencies as required.Safety Assessment PrinciplesIn addition to the Site Licence Conditions, HSE issued revised Safety Assessment Principles(SAPs) in 2006 for its inspectors to guide regulatory decision making which included principlesfor radioactive waste. Those applicable to development of the IWS are SAPs 646-683 onradioactive waste and those engineering principles relating to the control of nuclear matter. Theradioactive waste SAP recommendations are:• RW 1 - A strategy should be produced and implemented for the management of radioactivewaste on a site.• RW 2 - The generation of radioactive waste should be prevented or, where this is notreasonably practicable, minimised in terms of quantity and activity.• RW 3 - The accumulation of radioactive waste on site should be minimised.• RW4 - Radioactive waste should be characterised and segregated to facilitate subsequentsafe effective management.• RW 5 – Radioactive waste should be stored in accordance with good engineering practiceand in a passively safe condition.• RW 6 – Radioactive waste should be processed into a passively safe state as soon asreasonably practicable.• RW 7 – Information that might be required and in the future for the safe management ofradioactive waste should be recorded and preserved.EURATOM (European Atomic Energy Community) Treaty requirementsTwo Articles of the Euratom Treaty are of particular significance to radioactive wastemanagement. They are:• Article 35: Member Countries must establish facilities to monitor continuously the levelsof radioactivity in the air, water and soil, and to ensure compliance with standards.• Article 37: Member States to provide the Commission with such general data relating toany plan for the disposal of radioactive waste in whatever form as will make it possible todetermine whether the implementation of such plan is liable to result in the radioactivecontamination of the water, soil or airspace of another Member State.In addition, the European Union Council has issued a Directive laying down basic safetystandards for the protection of workers and the general public against the dangers arising fromionising radiation. The Basic Safety Standards Directive is implemented in the UK by IRR99,EPR2010 and other national legislation.RSRL IWS (Issue 5 – October 2012)111

NOT PROTECTIVELY MARKEDOSPAR ConventionThe UK Strategy for radioactive discharges aims, in part, to deliver the UK’s obligations underthe OSPAR Radioactive Substances Strategy, in respect of progressive and substantialreductions in radioactive discharges to the maritime area covered by the OSPAR Convention(Convention for the Protection of the Marine Environment of the North-East Atlantic) andpollution from ionising radiation. The OSPAR objective for 2020 is to reduce discharges tolevels where the additional concentrations in the marine environment above historic levels,resulting from such discharges, are close to zero. The UK Strategy addressing theserequirements was updated in July 2009 [ 17 ].Requirements of the ONR (Civil Nuclear Security) (CNS)The regulation of security in the civil nuclear industry is carried out by the ONR (Civil NuclearSecurity) department. CNS sets requirements for the protection of nuclear material on sites orin transit, against the risks of theft or sabotage, and for the protection of sensitive nuclearinformation, such as site security arrangements. CNS conducts its regulatory activities onbehalf of the Secretary of State for Energy and Climate Change (DECC) and ensurescompliance with the relevant requirements of the Anti-Terrorism, Crime and Security Act 2003and the Nuclear Industries Security Regulations 2003 (NISR 2003). The core requirement ofNISR2003 is for operators to submit a security plan for each site to CNS for approval, settingout the proposed security arrangements, and to comply with the provisions of the plan onceapproved. CNS also undertakes vetting of nuclear industry personnel with access to sensitivenuclear material or information. It works in close conjunction with nuclear security policy officialsin DECC and with other government departments and agencies, and with overseascounterparts.Radioactive Substances Regulation Environmental Principles (REPs) and Assessment of BestAvailable Techniques (BAT)The Environment Agency has developed the Radioactive Substance Regulation EnvironmentalPrinciples (REPs) to form a consistent and standardised framework for the technicalassessments and judgements that are made for the regulation of radioactive substances. Theyprovide guidance that help underpin EA decisions, including those about permitting andcompliance, and necessitate the use of Best Available Techniques (BAT) by operators.Environmental Permitting (England and Wales) Regulations 2010 (EPR2010)The Environmental Permitting Programme is a joint Environment Agency, Defra and WelshAssembly Government initiative which will streamline the environmental permitting andcompliance systems for obtaining, varying and transferring permits, authorisations andconsents. These Regulations replace the Environmental Permitting (England and Wales)Regulations 2007, and now includes the permitting and compliance requirements of other Actsand Regulations, including Radioactive Substances Act (RSA93) authorisations and theGroundwater Protection Regulations. It also defines the use of BAT to replace BPEO and BPM,such that:The term BAT means the latest stage of development (state of the art) of processes, of facilitiesor of methods of operation which indicate the practical suitability of a particular measure forlimiting discharges, emissions and waste. In determining whether a set of processes, facilities17 http://decc.gov.uk/en/content/cms/what_we_do/uk_supply/energy_mix/nuclear/issues/radioactivity/-radioactivity.aspxRSRL IWS (Issue 5 – October 2012)112

NOT PROTECTIVELY MARKEDand methods of operation constitute the best available techniques in general or individualcases, special consideration shall be given to:a) comparable processes, facilities or methods of operation which have recentlybeen successfully tried out;b) technological advances and changes in scientific knowledge and understanding;c) the economic feasibility of such techniques;d) time limits for installation in both new and existing plants;e) the nature and volume of the discharges and emissions concerned.The Best Available Technique for a particular process will change with time in the light oftechnological advances, economic and social factors, as well as changes in scientificknowledge and understanding.The use of BAT replaces BPM and BPEO, and is expected to deliver the equivalent level ofenvironmental protection as achieved previously by the use of BPM and BPEO.An amendment to EPR 2010 in October 2012 entirely superseded the Radioactive SubstancesAct 1993 which, up until that point, was still the reference for the exclusion and exemption ofradioactive wastes from radioactive substances control.Requirements that were previously regulated under the Landfill (England and Wales)Regulations 2002 are now regulated under EPR2010. The main requirement is that waste mustbe treated before it is disposed of at non-hazardous and inert landfills. This requirementalready applies to hazardous waste. Treatment is intended to reduce the amount of wastegoing to landfill and reduce the impact of waste when it is landfilled. Landfills cannot acceptuntreated waste. Therefore waste producers need to treat the waste themselves or ensure thatit is treated elsewhere before being landfilled. Liquid wastes are now banned from landfills.Treatment is defined by a three-point test, and all criteria must be satisfied for the waste to havebeen treated:• be a physical, thermal, chemical or biological process including sorting• change the characteristics of the waste• change the waste to reduce its volume or hazardous nature, facilitate its handling orenhance its recovery.These regulations also apply to contaminated non-hazardous soils. Currently, waste arisingfrom remediation of contaminated land which is disposed of at landfill may be the subject of areduced tax rate upon agreement from HMRC.Protection of the Environment through Criminal LawAn EU Directive (2008/99) on the protection of the environment through criminal law waspublished on 6 December 2008. This obliges Member States to provide criminal penalties intheir national legislation for cases of serious infringements of EU environmental law. MemberStates implemented the provisions of this Directive in national law in December 2010.Contaminated Land RegulationIn December 2007, amended regulations came into force The Radioactive Contaminated Land(Modification of Enactments) England (Amendment) Regulations 2007) so that Part 2A of theEnvironmental Pollution Act is able to address ‘off-site’ radioactive contamination from nuclearoccurrences in line with the ‘polluter pays’ principle regarding environmental liabilities.RSRL IWS (Issue 5 – October 2012)113

NOT PROTECTIVELY MARKEDSite Waste Management Plans (SWMP)The Site Waste Management Plans Regulations 2008 require construction sites to produce aplan that details the amount and type of waste that will be produced and how it will be reused,recycled, or disposed of. The plan is updated during the construction or demolition process torecord how the waste is managed and to confirm the disposal of any materials that cannot bereused or recycled at a legitimate site. RSRL procedure PRC0199 requires projects tocomplete a SWMP for each project with a value in excess of £300k. The RSRL IWS is used tocomplement the detailed given by project SWMPs.Waste Framework Directive 2008/98/ECIn 2004 the European Commission produced a proposal to revise the Waste FrameworkDirective (2006/12/EC) to differentiate clearly between recovery and disposal and to clarify thedistinction between waste and non-waste. It also introduced procedures for establishingminimum quality standards and required Member States to develop national waste preventionprogrammes.The 2008/98/EC Directive will repeal and replace the Waste Framework Directive (2006/12/EC),the Hazardous Waste Directive (91/689/EEC) and the Waste Oils Directive (75/439/EEC). Theapproach takes into account the whole life-cycle of products and materials and not only thewaste phase, and focuses on reducing the environmental impacts of waste generation andwaste management, thereby strengthening the economic value of waste. Member States mustimplement this Directive in national legislation by 12 December 2010.In 2010, Defra and the Welsh Assembly Government (WAG) invited views on the second stageconsultation on the transposition of the revised Waste Framework Directive (rWFD) in Englandand Wales which concluded in September 2010.The new Waste (England and Wales) Regulations 2011 came into force on 29 March 2011.They update some aspects of waste controls. The need for waste permits and authorisations forcertain activities therefore does not change. Most radioactive waste is controlled throughregulation as radioactive waste. All wastes which are outside of the scope of regulation asradioactive waste fall within the scope of regulation as Controlled Waste according to the newWaste (England and Wales) Regulations.Fluorinated Greenhouse Gases Regulations 2008Most fluorinated gases are very powerful greenhouse gases which contribute to global warmingif emitted to the atmosphere. The relevant gases that fall under the EC Regulation are:hydrofluorocarbons (HFC), perfluorocarbons (PFC), and sulphur hexafluoride (SF6).The Fluorinated Greenhouse Gases Regulations came into force on 15 February 2008 andprescribe offences and penalties to infringements of the following provisions:• Leakages• Leakage checking and leak detection systems• Record keeping• Instruction manuals• Recovery of gases• Existing qualifications for personnel working on equipmentRSRL IWS (Issue 5 – October 2012)114

NOT PROTECTIVELY MARKEDRadioactive Low Level Waste (LLW) PolicyAs previously discussed, the Government issued its new policy for the long term managementof solid low level radioactive waste in March 2007. The policy updated Cm2919 in:• Allowing greater flexibility in managing in the wide range of LLW that already exists andwill arise in the future, proposing that a risk based approach is used in selecting disposaloptions;• Giving NDA the remit for creating a UK-wide strategy for managing low level waste fromthe nuclear industry, including at what point in the future a replacement (orreplacements) for the national disposal facility near Drigg in Cumbria (LLWR) might berequired and planned;• Permitting export of LLW to other OECD and EU countries for the recovery of re-usablematerials, or for treatment that will make its subsequent storage and disposal moremanageable where this has been demonstrated and authorised as the best practicableoption.The policy also gave new definitions for the lower activity end of the LLW, namely givingthe two new categories of Low Volume and High Volume Very Low Level Waste (VLLW).The activity of High Volume VLLW can be up to 4Bq/g except for tritium which is allowedup to 40Bq/g.RSRL is represented at the LLW Steering Group which continues to take forward theUK-wide strategy for managing LLW for the NDA and hence maintains awareness ofdevelopments which may impact on the management of LLW at the RSRL sites. TheNDA issued the UK Strategy for the Management of Solid LLW for the Nuclear Industryin August 2010 and this supports the use of off-site waste disposal routes for Harwelland Winfrith VLLW and HV-VLLW.Dedicated disposal facilities may be developed solely for LLW or HV-VLLW. These maybe situated on or off nuclear sites. An operator of such a site will need to hold anenvironmental permit for disposal of radioactive waste. The Environment Agency shouldalso consider the non-radiological impact of the radioactive waste being disposed of andmay place conditions in the environmental permit in relation to such non-radiologicalproperties.These Regulations have removed the previous requirement under RSA 93 thatapplications for disposal are sent to the Local Authorities where it is proposed to sendwaste for disposal. As a result it is not necessary for permits to identify specific site(s) atwhich the waste will ultimately be disposed of. Permits allow the transfer to any sitewhere the operator of that site holds an environmental permit to accumulate or disposeof the relevant type of waste, or for HV-VLLW to any site disposing of conventionalwaste. However, the Environment Agency may identify specified sites in permits asnecessary to meet the requirements of Government policy, for example to deliver therequirements of the proximity principle and the waste hierarchy. Records of wastetransfers must be kept by both the consignor and the receiving site operator.Other Regulatory ConstraintsThere are no licence instruments or improvement notices on waste management issues ateither RSRL site. RSRL has however recently received an improvement notice relating tocontrol of work, supervision and training and this is due to be closed out by December 2012.RSRL IWS (Issue 5 – October 2012)115

NOT PROTECTIVELY MARKEDLegal interpretation of the requirements for certain wastes with potential for dual control underradioactive and non-radioactive waste legislation may be required. For instance; whether LA-LLW or HV-VLLW authorised for disposal is also managed the same way under the WasteManagement Licensing or Landfill Regulations (that it would come under were it not for itsradioactive properties) and the classification and transfer of hazardous, non-hazardous or inertwaste that is regulated under exemption orders to the EPR2010.RSRL IWS (Issue 5 – October 2012)116

NOT PROTECTIVELY MARKEDANNEX 4: GLOSSARY AND ACRONYMSGlossaryALARA (As Low As Reasonably Achievable)To satisfy the ALARA Principle, radiological doses and risks are kept as low as reasonablypracticable, taking a proportionate approach, whereby priority is given to reducing dischargeswhich have greatest radiological significance or which present most risk of damaging the marineenvironment, whilst ensuring that the costs of such reductions are not grossly disproportionateto their benefits in line with current Government guidance on better regulation.ALARP (As Low As Reasonably Practicable)To satisfy the ALARP Principle, measures necessary to reduce risk are undertaken until orunless the cost of these measures, whether in money, time or trouble, is disproportionate to thereduction in risk.Best Available Technique (BAT)The term "best available techniques" means the latest stage of development (state of the art) ofprocesses, of facilities or of methods of operation which indicate the practical suitability of aparticular measure for limiting discharges, emissions and waste."Techniques" include both the technology used and the way in which the installation isdesigned, built, maintained, operated and dismantled.Best Practicable Environmental Option (BPEO)The waste management option that is the outcome of a systematic and consultative decisionmakingprocedure that emphasises the protection and conservation of the environment acrossland, air and water. The BPEO procedure establishes, for a given set of objectives, the optionthat provides the most benefit or least damage to the environment as a whole, at acceptablecost, in the long term as well as in the short term.Best Practicable Means (BPM)BPM is a term used by historically by EA in authorisations issued under the RadioactiveSubstances Act (RSA93). Essentially, it requires operators to take all reasonably practicablemeasures in the design and operational management of their facilities to minimise dischargesand disposals of radioactive waste, so as to achieve a high standard of protection for the publicand the environment. BPM is applied to such aspects as minimising waste creation, abatingdischarges and monitoring plant, discharges and the environment. It takes account of suchfactors as the availability and cost of relevant measures, operator safety and the benefits ofreduced discharges and disposals. If the operator is using BPM, radiation risks to the publicand the environment will be ALARA.CharacterisationCharacterisation of radioactive materials involves analysing the materials in terms of theirphysical and chemical form, radioactive content, origin, present state, current storage conditionsand other relevant information and properties. This radiological characterisation may involveobtaining data from several sources:• Reviewing existing information. Such as historical facility usage records and radiologicalsurvey data• Calculations using codes for activation, nuclear fuel burn-up, and radioactive decay• In situ measurements e.g. taking swabs and measuring using a dose rate counter• Sampling and analysis – accurate characterisation requires representative sampling ofmaterials (for example non-homogeneous samples (e.g. concrete) require carefulsampling and homogenisation to ensure that representative samples are taken forRSRL IWS (Issue 5 – October 2012)117

NOT PROTECTIVELY MARKEDanalysis. If contamination is not uniform, but an “averaged” value of activity is required,then some form of systematic sampling (e.g. using a grid) and homogenisation of thesamples should be used.• DocumentationCharacterisation is an essential step at the beginning of the decommissioning processand may need to be repeated at different stages during the decommissioning. For moreinformation, refer to “Radiological Characterisation of Shutdown Nuclear Reactors forDecommissioning, IAEA Technical Report Series No. 389, IAEA, Vienna (1998).CleanAn article or substance which has had no reasonable potential to have become contaminated oractivated, or upon or within which no radioactivity other than normal background is detectablewhen suitable comprehensive measurement (monitoring and sampling) is practicable and hasbeen undertakenClearanceThe process to confirm that an article or substance is clean (free from radioactivity), or exempt(outside of the scope of regulation as radioactive material) from further control under all relevantlegislation on the basis of its radioactivityClinical WasteThis is controlled waste that includes any waste which consists wholly or partly of human oranimal tissue, blood or other bodily fluids, swabs, needles, or sharp instruments. Clinical wasteis classified as industrial waste for legislative purposes however it is also subject to theHazardous Waste Regulations.Commercial WasteCommercial Waste includes wastes from premises used for a trade or business or for thepurposes of sport, recreation or entertainment e.g. general office wastes.Controlled WasteThis includes industrial and commercial waste (s.75 of EPA 1990 as modified by the WasteManagement Licensing Regulations 1994) both of which are subject to control by theEnvironment Agency under waste management regulations. Controlled waste can be inert,hazardous or non-hazardous.Directive WasteThis is any substance or object which the producer or the person in possession of it discards orintends or is required to discard. This forms the basic definition of waste in the UK. Othercategories of waste are subsets within Directive Waste.DesignationUnder the Energy Act 2004 the Nuclear Decommissioning Authority (NDA) has responsibilityfor, amongst other things, the decommissioning of designated nuclear installations and thecleaning-up of designated nuclear sites. The designation of installations, sites and facilities issubject to the form of a direction to the NDA given by the appropriate Secretary of State.DelicensingDelicensing is referred to by the ONR as meaning “ending of the period of responsibility underThe Nuclear Installations Act”. This is defined in section 5(3) of the Nuclear Installations Actand can only happen when the HSE gives notice in writing to the licensee that it its opinionthere has “ceased to be any danger from ionising radiations from anything on the site or, as thecase may be, on that thereof”. Before delicensing any land on nuclear site, HSE must satisfyitself that delicensing is appropriate and that licensable activities are no longer being carried outRSRL IWS (Issue 5 – October 2012)118

NOT PROTECTIVELY MARKEDon the site or that part of the site to be de-licensed. This means that no radioactive wasteremains on the site or the part of the site to be delicensed.The HSE has indicated that for practical purposes the criterion of ‘no danger’ for the purpose ofde-licensing is an additional risk of death to an individual of one in a million per year (10 -6 ).Compliance with this criterion would normally mean that HSE can remove the site fromregulatory control under NIA65.Exempt (‘Out of Scope’)A radioactive or contaminated article or substance that does not exceed the individual radionuclidelimits specified under EPR2010 and can therefore be deemed to be ‘out of scope’ ofregulation as a radioactive material.Final End StateThe ‘end state’ of a site is the physical condition at the point when the NDA has finished itsbusiness. The ‘end point’ of a site is the time at which this ‘end state’ is reached.HandoffWaste stream for which an agreement has been made for transfer to a third party fortreatment/processing/storage and/or disposalHazardous Wastes (formerly also known as Special Wastes)Hazardous waste is controlled waste that contains any substance specified in The HazardousWaste (England and Wales) Regulations 2005, ISBN 0110726855. Radioactivity does not initself make waste hazardous waste. However radioactive waste may posses other properties,such as toxicity due to the presence of uranium, which bring it within the definition of hazardouswaste and therefore subject to the requirements of the Hazardous Waste Regulations, inaddition to the requirements of the Radioactive Substances Act 1993.Examples of typical hazardous wastes are• Scheduled poisons - (Schedule 1 of the Appendix to the Poisons Rules, 1982, StatutoryInstrument No 218). This Schedule includes, amongst others, cyanides and compoundsof barium, arsenic, thallium and mercury. Also includes significant quantities (greaterthan 10 grams per day) of copper, chromium, lead, cadmium, nickel, vanadium, zinc andother heavy metals.• Laboratory and other chemicals;• Drugs and/or medicines;• Aerosols containing paints, adhesives, lubricants and cleaners;• Asbestos;• Bio-hazardous waste;• Batteries, other than household;• Pesticides and weed killers;• Solvent based resins, paints and adhesives, paint strippers or similar materials fromphotographic or copying processes;• Waste oils, oil filters, oil water mixtures and crude oilNote - The methodology for classifying wastes as hazardous is based, in part, on decidingwhether the waste possesses hazardous properties, which requires knowledge of the chemicalcomposition of the waste. Assessing the hazardous properties is based the classificationprocedure for chemical products under the Chemicals (Hazard Information and Packaging forSupply) Regulations 1994 (as amended) (CHIP), although there are some modificationsintroduced by the Hazardous Waste Directive.High Volume Very Low Level WasteRSRL IWS (Issue 5 – October 2012)119

NOT PROTECTIVELY MARKEDHV-VLLW comprises building rubble and soil from decommissioning and site remediation withactivity levels at the lower end of LLW. If this large volume of waste were to be consigned tothe LLWR, the volumetric capacity would be seriously compromised. New definition of highvolume Very Low Level Waste most appropriate: Radioactive waste with maximumconcentrations of 4 Becquerel’s per gram (Bq/g) of total activity which can be disposed of tospecified landfill sites. For waste containing hydrogen-3 (tritium), the concentration limit fortritium is 40 Becquerel’s per gram (Bq/g) (March 2007 LLW Policy).Industrial WastesThis is controlled waste that includes wastes from a factory, wastes from laboratories,workshops, construction and demolition works, and clinical waste.Inert WastesInert waste is controlled waste that is defined in the Landfill Directive as waste that does notundergo any significant physical, chemical or biological transformations. Inert waste will notdissolve, burn or otherwise physically or chemically react, biodegrade or adversely affect othermatter with which it comes into contact in a way likely to give rise to environmental pollution orharm human health. The total leachability and pollutant content of the waste and the ecotoxicityof the leachate must be insignificant, and in particular not endanger the quality of surface waterand/or groundwater.Interim End State (Winfrith)The site will be passively managed by applying land use restrictions whilst residual radioactivitydecays. After a period of time (envisaged to be decades), the site will reach a condition when itcan be de-licensed then de-designated at which pint the land use restrictions will no longer berequired.Intermediate Level Waste (ILW)ILW is defined as waste with a radioactivity level that exceeds the upper boundaries for lowlevel waste (4,000 Bq/g α and 12,000 Bq/g β/γ) but which does not require heating to be takeninto account in the design of storage or disposal facilities (Cm2919).Letter of Compliance (LoC) (formerly Letter of Comfort)Under its Letter of Compliance system, in the context of a phased approach to disposal, RWMDprovides guidance to the nuclear industry on its requirements for the packaging and transport ofILW. LoC’s are issued in three stages, which successively assess the suitability of theproposals against the requirements for safe disposal against the phased disposal concept.Lower Activity Low Level Waste (LA-LLW)Material at the lower end of LLW. The activity limits for LA-LLW are dependent on theconditions for acceptance given on the permit held by the receiving site. In the case of the offsiteroute established in the last year this is up to 200Bq/g.Low Level Waste (LLW)LLW is now defined as: ‘radioactive waste having a radioactive content not exceeding fourgigabequerels per tonne (GBq/te) of alpha or 12 GBq/te of beta/gamma activity’ (March 2007LLW Policy).Non-Hazardous WastesThis is controlled waste which is not covered by the definition of hazardous waste. It comprisesboth inert waste and putrescible waste. Putrescible waste is controlled waste that willdecompose readily under microbial attack. It includes green waste and wastes arising fromresidential, commercial and industrial sources.RSRL IWS (Issue 5 – October 2012)120

NOT PROTECTIVELY MARKEDPassive SafetyONR’s guidance to its inspectors defines passive safety in the following way:"Passive safety…..requires…..radioactive wastes…..to be immobilised in a form that isphysically and chemically stable and stored in a manner which minimises the need forcontrol and safety systems, maintenance, monitoring and human intervention. Thewastes…..should be stored in discrete packages which are resistant to degradation andhazards and which can be inspected and retrieved for final disposal."Proximity PrincipleThe proximity principle requires waste to be disposed of as close to the place of production aspossible. This avoids passing the environmental costs of waste management to communitieswhich are not responsible for its generation, and reduces the environmental costs oftransporting waste. In considering waste management options there should be assessment ofwhere environmental burdens fall in relation to particular sectors of society and recognition ofpotential adverse impacts on health and quality of life, in relation to other potential benefits tothe social and economic needs of the area. The proximity principle has been defined primarilyfor non-radioactive wastes. For radioactive wastes it is a consideration to be taken intoaccount, rather than an absolute principle. Most radioactive wastes that exist or will arise in thefuture will be owned by a small number of mainly public bodies (such as the NDA). For practicalpurposes radioactive waste creation and waste management are as closely linked as possible.Consideration needs to be given to balancing the impacts of waste transport against theconcentration of radioactive wastes to ensure they can be securely and safely managed.Robust Concrete BoxAn IP-2 rated radioactive transport package (previously known as the WAGR box).Secondary WasteThis is waste produced as a by-product of processing the primary waste stream.Nuclear Material (NM)“Nuclear Material" (NM) is defined by Title I of the Atomic Energy Act of 1954 as plutonium,uranium-233, or uranium enriched in the isotopes uranium-233 or uranium-235. The definitionincludes any other material that the Commission determines to be nuclear material, but doesnot include source material. The IWS will cover NM that is currently identified as a waste orwhere it may be destined for a waste route in the future.Sustainability – Sustainable DevelopmentThis has been widely defined as ‘development which meets the needs of the present withoutcompromising the ability of future generations to meet their own needs. The followingrequirements should be met:• Waste management should not impose undue burdens on future generations and theirenvironment such that it compromises their ability to meet their needs.• Even given a legacy of appropriate financial resources, future generations should preferablynot have to divert time and effort to managing wastes generated by present and pastgenerations. They should be free to pursue their own preoccupations.• Decisions should be based on the best possible scientific information and analysis of risks• Where there is uncertainty and potentially serious risk exists, precautionary action may benecessary• Ecological impacts must be considered, particularly where resources are non-renewable oreffects may be irreversible• The underlying principle of “polluter pays” should be recognised in assessing costimplications (the ‘polluter pays’ principle requires producers and owners of wastes to bearthe costs imposed by those wastes, including the costs of regulation and those of relatedresearch undertaken both by themselves and by the regulatory bodies. The evaluation ofRSRL IWS (Issue 5 – October 2012)121

NOT PROTECTIVELY MARKEDenvironmental and human costs of waste production, treatment and disposal should also betaken into account).Sustainable development should be taken into account as one of the relevant considerations inconsidering the development of the site IWS and of waste management policy.Traffic Light SystemThe NDA Traffic Light System is used to describe the status of on inter-site transfers.A ‘RED’ status is where Site A has the transfer in their LTP as an opportunity. However, Site Bdoes not have any recognition of the transfer in their baseline. In fact it may be defined as anexclusion in Site B’s baseline. There are therefore a number of issues that remain to beresolved. Site A must produce a Framework Plan to resolve these issues and reach agreementwith Site B on the transfer. Site A may also use the red status to highlight future strategieswhere Site B has yet to be identified.An “AMBER” status is where Site A has the transfer in their LTP programme as an opportunity.Site B also has the transfer in their LTP as an opportunity. The scope, schedule and cost of thetreatment, storage and disposal of waste or nuclear material should be in the donor sites LTPuntil the transfer is enabled via change control. The recipients sites LTP will be amended toreflect the transfer. The two sites are working together to resolved the actions identified in theFramework Plan. The sites have demonstrated that the transfer is technically feasible.However, there remain a number of stakeholder engagement and/or other issues to be resolvedbefore the transfer can be agreed.A “GREEN” status is where Site A has the transfer in its Baseline and Site B also has thetransfer in its Baseline. The actions in the Framework Plan have been completed. Fullstakeholder engagement has also been completed and the transfer authorisation is in place.There may remain some minor issues which still need to be resolved on the detailed operationallevel but there are no known “showstoppers”. The transfer is reflected in both sites IntegratedWaste Strategy documents.UndesignateUndesignate is the revocation of a direction by the Secretary of State to the NDA for thedesignation of an installation, site or facility. The direction can only be revoked once theSecretary of State (jointly with Scottish Ministers for installations, sites and facilities in Scotland)is satisfied that the NDA has discharged all its responsibilities in relation to thedecommissioning or cleaning-up of the installation or site.Waste HierarchyThe Waste Hierarchy encourages the adoption of options for managing waste in the followingorder of priority:• Waste should be prevented or reduced at source as far as possible• Where waste cannot be prevented, waste materials or products should be reused directly orrefurbished then reused• Waste materials should then be recycled or reprocessed into a form that allows them to bereclaimed as a secondary raw material• Where useful secondary materials cannot be reclaimed, the energy content of waste shouldbe recovered and used as a substitute for non-renewable energy resources• Only if waste cannot be prevented, reclaimed or recovered, should it be disposed of into theenvironment and this should only be undertaken in a controlled manner.RSRL IWS (Issue 5 – October 2012)122

NOT PROTECTIVELY MARKEDAcronymsAHFActive Handling FacilityALARAAs Low As Reasonably AchievableALARPAs Low As Reasonably PracticableALESActive Liquid Effluent SystemATOAuthority To OperateAWOArea Waste OfficerBATBest Available TechniqueBEPO British Experimental Pile “0”BoSSBalance of Site StructuresBPEOBest Practicable Environmental OptionBPMBest Practical MeansCHILWContact-handled ILWCHIPChemicals (Hazard information and Packaging for Supply)CIRIAConstruction Industry Research & Information AssociationCLDConcrete Lined DrumCoLACommon Low Activity (materials)CoRWMCommittee on Radioactive Waste ManagementCWBSCompany Work Breakdown ScheduleDEFRADepartment of Environment Fisheries and Rural AffairsDUDepleted UraniumEAEnvironment AgencyEASTExternal Active Sludge TankEPREnvironmental Permitting RegulationsEURATOMEuropean Atomic Energy CommunityFMSFissile Material StoreGDFGeological Disposal FacilityGISGeographical Information SystemGLEEPGraphite Low Energy Experimental PileHECHead End CellsHEPAHigh Efficiency Particulate in AirHHISOHalf Height ISO containerHSEHealth and Safety ExecutiveHSWAHealth and Safety at Work ActHV-VLLWHigh Volume Very Low Level WasteHWMMHarwell Waste Management MeetingHZWHazardous WasteIAEAInternational Atomic Energy AuthorityILWIntermediate Level WasteIMAGESInformation Management and Geographical Evaluation SystemIRRIonising Radiations RegulationsISOInternational Organisation for StandardisationISRSInternational Safety Rating SystemIWSIntegrated Waste StrategyLA-LLWLow Activity Low Level WasteLDFLead Decontamination FacilityLETPLiquid Effluent Treatment PlantLEULow Enriched UraniumLLWLow Level WasteLLWRLow Level Waste RepositoryLoCLetter of Compliance (historically Letter of Comfort)LSGLocal Stakeholder GroupLTPLifetime PlanMCSModular Containment SystemRSRL IWS (Issue 5 – October 2012)123

NOT PROTECTIVELY MARKEDNDANDSNHZNIANMNMADNUOMADONROPCOSPARPCPPEWPFAPIEPOCOPPARAMRETPRCBRCFRHILWRMRSARSRLRWMDRWPGSD:SPURSFLSGHWRSLCSSSSSSISWCSWMPSWTCTBDTBURDTHISOTRSUKWACMWAGWAMACWEPWETPWMGWRATsZEBRANuclear Decommissioning AuthorityNational Disposal ServiceNon-Hazardous WasteNuclear Installations ActNuclear MaterialNew Main Active DrainNatural UraniumOld Main Active DrainOffice for Nuclear Regulation (was the Nuclear Installations Inspectorate)Ordinary Portland CementOslo Paris ConventionProgramme Controls ProcedurePotentially Exempt WastePulverised Fuel AshPost Irradiation ExaminationPost Operational CleanoutProcess and Packaging Area (Harwell Solid Waste Complex)Radio-Active MaterialReplacement Effluent Treatment PlantRobust Concrete BoxRadio-Chemical FacilityRemote Handled ILWRetrieval Machine (Harwell)Radioactive Substances ActResearch Sites Restoration LtdNDA Radioactive Waste Management DirectorateRadioactive Waste Policy GroupSite Decommissioning: Sustainable Practices in the Use of ResourcesSpringfields Fuels LtdSteam Generating Heavy Water ReactorSite Licence CompanySite Strategic SpecificationsSite of Special Scientific InterestSolid Waste ComplexSite Waste Management PlanStandard Waste Transport ContainerTo Be DeterminedTechnical Baseline and Underpinning R&D DocumentThird Height ISO containerTreated Radwaste StoreUnited KingdomWinfrith Abrasive Cleaning MachineWelsh Assembly GovernmentWaste Monitoring and Compaction Facility (Sellafield)Waste Encapsulation Plant (Harwell)Winfrith EAST Treatment PlantWaste Management GroupWastes Requiring Additional TreatmentZero Energy Breeder Reactor AssemblyRSRL IWS (Issue 5 – October 2012)124