IWS Action Plan. April 2014

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1 IWS Action Plan April

2 Magnox Integrated Decommissioning and Waste Management Strategy Action Plan Owner: Peter Roach Strategic Programmes Signature: Date: 23 rd April Published in the United Kingdom by Magnox Limited, Berkeley Centre, Berkeley, Gloucestershire, GL13 9PB. All rights reserved. No part of this publication may be: (i) reproduced used, dealt with, possessed or transmitted in any form or by any means, including photocopying and recording, without the written permission of the copyright holder; or (ii) used, dealt with or possessed in any way whatsoever, where such use, dealing with or possession will or may infringe any intellectual property rights of the publisher (including any trade marks, patents or patents pending, design right (registered or unregistered), know how, show how, moral rights or any licence held by the publisher with a third party). Application for permission to reproduce, transmit, use, deal with or possess should be addressed to the publisher. Such written permission must also be obtained before any part of this publication is stored in a retrieval system of any nature. Requests for copies of this document should be referred to: Waste Programme, Berkeley Centre, Berkeley, Gloucestershire, GL13 9PB Magnox Limited 2 IWS Action Plan,

3 Introduction Background The Nuclear Decommissioning Authority (NDA) is a strategic authority established in 2005 under the Energy Act It is responsible for decommissioning and cleaning up civil nuclear facilities; ensuring that all the waste products are safely managed; implementing government policy on the long term management of nuclear waste; and developing UK-wide nuclear low level waste (LLW) strategy and plans. The NDA strategy is delivered through management and operations contracts with licensed operators: site licence companies. Magnox (the company) is the management and operations contractor responsible for ten nuclear sites and one hydroelectric plant in the UK working for the sites owner, the NDA. Figure 1: Magnox Sites 1. Hunterston A 2. Chapelcross 3. Wylfa 4. Trawsfynydd and Maentwrog 5. Berkeley 6. Oldbury 7. Hinkley Point A 8. Dungeness A 9. Bradwell 10. Sizewell A Action Plans There is a requirement from the NDA, and an expectation from the regulators, that the company will develop and maintain an Integrated Waste Strategy (IWS). Magnox fulfils this requirement through the production of S-036, Integrated Decommissioning and Waste Management Strategy. The strategy applies to all company nuclear licensed sites (and associated land-holdings), and all their wastes, ie intermediate level waste (ILW), low level waste (LLW), very low level waste (VLLW), non-radioactive waste, aqueous and gaseous discharges. IWS Action Plan, 3

4 Any gaps, threats and opportunities identified throughout S-036 have been reviewed and the action plan contained within this document produced. The strategy and therefore this action plan will primarily be implemented through a series of strategic programmes established to deliver safe and efficient decommissioning of the sites in-line with the Magnox Optimised Decommissioning Programme (MODP). The programmes cover the main areas of decommissioning and waste management. They are: Figure 2 illustrates the interaction of the strategy within this document with government policy, NDA strategy, site underpinning and justification, and the reporting of progress on delivery of the company strategy. 4 IWS Action Plan,

5 S-036 covers the whole strategy period, ie to the end of final site clearance (FSC). As a minimum, review of this document will be undertaken on a cycle of no more than three years. This action plan will be reviewed annually. The review cycle is shown in Figure 3. Figure 3: Strategy and action plan review cycles FSC Strategy periods Strategy review cycle Action plan review Trigger IWS Action Plan, 5

6 Action Plan Action Objective Accountability Target Date Status 1. Ponds: Agreement of care and maintenance (C&M) entry condition for Trawsfynydd and Bradwell ponds. To inform assessment of C&M entry states for the remaining sites. Ponds Programme Bradwell: December 2015 Trawsfynydd: December 2016 Ongoing action from 2013 plan. Progress has been made in preparing the ponds for C&M entry. 2. MAETP: First of a kind modular active effluent treatment plant (MAETP) installed at Chapelcross. To enable dissemination of learning from Chapelcross to other sites. Ponds Programme May 2015 New action 3. ILW storage: Approval gained for first of a kind interim stage letter of compliance (iloc) for Bradwell waste streams. To enable the close out of generic iloc issues and enable the development of iloc submissions for other waste streams. To enable the development and deployment of conditioning solutions. ILW Programme December Ongoing action from 2013 plan. First of a kind interim stage iloc submissions have been prepared for the majority of the Bradwell waste streams. 4. ILW processing: Recovery and processing of 50 drums of wet ILW at Hunterston A complete. To enable the recovery and processing of wet ILW at Hunterston. ILW Programme March 2015 Ongoing action from 2013 plan. 5. ILW retrieval: All Bradwell bulk ILW retrieved. To enable the conditioning and interim storage of Bradwell ILW and entry into C&M. ILW Programme December New action 6. ILW processing: Placement of first conditioned waste package in the Berkeley interim storage facility (ISF). To prove the use of alternative conditioning plant and enable the roll out of the plant at the other Magnox sites. ILW Programme December New action Bradwell ponds sealing Bradwell pile cap deplanting 6 IWS Action Plan,

7 Action Objective Accountability Target Date Status 7. FED dissolution: Inactive and active commissioning of the Bradwell FED dissolution plant complete. To increase to TRL 9 and enable the Bradwell design to be used as a template for future plant. FED Programme May Ongoing action from 2013 plan. Dissolution and abatement plants have been constructed at Bradwell site. 8. FED dissolution: Completion of all FED dissolution at Bradwell. To enable progress toward C&M entry. FED Programme June 2015 New action 9. LLW management: Delivery of the joint low level waste management plan (JWMP). To embed the UK low level waste strategy within Magnox as part of a national waste programme. Waste Programme Ongoing (5 year rolling plan) New action 10. Non-rad waste management: Implementation of new simplified, standard non-radioactive waste management process. To increase efficiency and assurance of non-radioactive waste management practices. To allow transfer of skills between sites. Waste Programme March 2015 New action 11. C&M: Completion of all physical works at Bradwell to enable C&M entry in accordance with the safety case and stage submissions. To enable dissemination of learning from Bradwell C&M safety case submissions to all sites and other site licence companies. Plant & Structures Programme December 2015 Ongoing action from 2013 plan. A large amount of enabling works has been completed. The site continues to make progress towards C&M entry. 12. C&M: Bradwell site handover to the Hub. To enable the Hub to manage Bradwell site entering the quiescent C&M state. Hub September 2015 New action Bradwell boiler house deplanting Bradwell charge machine pressure vessel removal IWS Action Plan, 7

8 2013 Action Plan Status A summary of the completed actions from the 2013 Action Plan is reported on the next few pages. Note that 2013 Actions one, three, five, seven and nine have been carried over to the Action Plan. Action Objective Accountability Target Date Status 2. Pond skips: Completion of ponds skips decontamination trials. To determine the benefit of applying the technology. Ponds Programme October 2013 Complete 4. ILW storage: Placement of first conditioned waste package in the Bradwell ISF. To increase to technology readiness level (TRL) 9 and enable Bradwell design to be used as a template for future stores. ILW Programme March Complete 6. FED dissolution: Cumulative 16 Te of Bradwell FED dissolved (processed and discharged) at Dungeness A. To maximise the use of existing assets and to progress with the treatment of waste. FED Programme March Complete 8. Decommissioning: Project standard models in place for plant and structures projects. To enable a standardised approach across the sites to be undertaken during deplanting and decommissioning. Plant & Structures Programme March Complete 10. LLW management: Delivery of the JWMP. To embed the UK low level waste strategy within Magnox as part of a national waste programme. Waste Programme Ongoing (5 year rolling plan) Complete 11. Waste strategy: Delivery of the NDA gate B strategic management system (SMS) papers on ILW storage optimisation and FED treatment optimisation. To enable preferred options to be identified and the optimised solution implemented. Waste Programme March Complete 12. C&M: Completion of enabling activities to establish the Hub model. To enable the central management of sites when they enter C&M. Hub March Complete 8 IWS Action Plan,

9 Action #2 Pond skips decontamination trial Trials to investigate innovative methods of decontaminating pond skips have been completed by the Ponds Programme at Hinkley Point A, with the results far exceeding the expectations of the team. Several test skips which had 1.2mm of paint and steel removed by computer guided milling machines, resulting in reclassifying the skips to outof-scope material. The trials have shown that removing 20 per cent of a skip s mass by milling also removes all detectable radioactivity, meaning that the remaining skip metal can be recycled without needing to be treated as ILW or LLW. This will result in significant savings to the taxpayer. Out of the remaining 511 skips across the Magnox sites, approximately 70 per cent are currently classed as ILW. Action #4 Creation of disposable ILW packages at Bradwell Construction of Bradwell ISF The first ISF constructed at a Magnox site was officially opened at Bradwell in August The facility, covered with more than 2,300m 3 of aluminium cladding, will be used to store ductile cast iron containers (DCICs) containing conditioned ILW until the geological disposal facility (GDF) is available in the future. The building was designed with C&M in mind. The curved roof has been engineered so that rain water will simply run off into drains without any need for guttering. This significantly reduces the amount of maintenance needed. All future ISFs will be based on the common scalable reference design developed for Bradwell. The design allows each site to reduce or increase the size of the store in line with its storage requirements, while retaining the same key design features. Bradwell sludge conditioning Work has also progressed with ILW conditioning at Bradwell with the FAVORIT conditioning system now in operation. This plant is used to dry the waste, creating disposable ILW packages in accordance with Radioactive Waste Management Limited requirements. Active sludge has for the first time on a Magnox site, been transferred to the conditioning plant in DCICs before being placed for interim storage in the site s ISF. Using this type of technology is a UK first and in doing so reduces the hazard associated with wet waste while reducing the volume of ILW for interim storage at Bradwell. Interim storage The placement of the first conditioned DCIC in the Bradwell ISF is seen as a large step towards C&M entry. Ongoing maintenance of disposability will be achieved through establishing a controlled storage environment and an appropriate inspection and monitoring regime. IWS Action Plan, 9

10 Action #6 Action #6 FED FED dissolution Action #8 Plant & Structures Action #8 Plant & Structures Programme Programme standard projects standard projects Action #11 Waste optimisation project Action #11 Waste optimisation project stakeholder engagement engagement Bradwell FED dissolution As of March 50% of the total FED has been retrieved from the vaults at Bradwell. The waste has been packaged into 200 litre drums, ready to be transferred to a dissolution facility for treatment. The construction of the Bradwell dissolution plant and abatement facility has also completed during 2013/14 and is now undergoing commissioning. Transport to Dungeness A About 20 Te of drummed FED from Bradwell was transferred to Dungeness A. This transfer has demonstrated the safe and secure transportation of FED between Magnox sites. This FED has been treated by the Dungeness A dissolution plant. The ongoing use of the Dungeness A plant makes good use of existing assets and help to maintain the plant in good working order while awaiting the outcome of the NDA FED treatment optimisation study (see action #11). Magnox has created a set of ten project models, each with a Haynestype manual that provides a standard and consistent approach to the following decommissioning activities: deplant and demolition demolition demolition The standard model approach was developed through learning lessons from Bradwell decommissioning and has now been successfully implemented at Dungeness A on the south side clearance project. Since the beginning of 2013, Magnox and the NDA have been engaging with stakeholders on considering the best locations for the interim storage of ILW packages and the treatment of FED. The current plan is to build an ISF and FED treatment facility at each site. The NDA review considers whether fewer facilities would bring environmental and financial benefits. Options assessment and stakeholder engagement was undertaken during 2013 to determine a preferred integrated option. This preferred option was submitted to the NDA and published for stakeholder comment see Following public feedback, if the NDA decides to proceed, work will begin in to prepare for implementation. Bradwell FED leaving for Dungeness A site Bradwell pile cap deplant 10 IWS Action Plan,

11 Action #10 Joint LLW Management Plan (JWMP) Information about the key areas of work and specific projects carried out by Magnox through implementing the JWMP during 2013/14 are contained within Issue 6 of the JWMP (March ) see achievements are presented below. LLW disposal diversion By applying the waste hierarchy Magnox sites have significantly reduced the volume of waste sent for disposal to the LLW Repository see diversion graph below. Over the last three years there has been almost a six-fold decrease in the volume of waste consigned to the repository despite a two to three-fold increase in total waste arisings due to an accelerated decommissioning programme. Magnox LLW disposal vs LLW/VLLW diversion routes 6000 LLW metal recycling LLW combustibles VLLW LLW disposal Volume m / / / / / / / / / /14 /15 Financial year Berkeley boilers The final ten iconic boilers were removed from the Berkeley site in March The boilers, which were transported through Berkeley town centre were loaded onto a River Severn barge at Sharpness docks then taken downriver to Avonmouth. From there the boilers were shipped aboard a seagoing vessel to Studsvik s nuclear licensed site, in Sweden, to be cut up, decontaminated and smelted. Clean steel ingots resulting from the process will be sold on the scrap metal market with any secondary waste returning to the UK for management as VLLW/LLW. At around 310 tonnes apiece, the absence of the 16 boilers has dramatically changed the landscape of the site. The first five boilers, removed last year, have now all been treated with between per cent of their metal recycled higher than predicted. During the financial year 2013/14 Magnox has diverted 93% of all LLW from the LLW Repository, including: 3 of combustible waste 3 of very low level waste (VLLW) Last boiler leaving Berkeley site Steel ingots from boiler smelting IWS Action Plan, 11

12 Action #12 C&M Hub Team Waste metrics The Hub team has now been set up for Magnox. The responsibility for the management of Magnox sites will be transferred to the Hub when they enter C&M. The Hub will: off-site team on-site presence and maintenance one way station reduction programme when available (England and Wales only) Hub arrangements have also been developed over the last year. An outline specification for security arrangements has been established, detailed designs are in progress. The permissioning routes for entering C&M have also been identified. Dialogue with the regulators about C&M entry is ongoing. Bradwell will be the first site to enter C&M and handover to the Hub. Images of what Bradwell might look like in 2015 are shown here. Bradwell during C&M 12 IWS Action Plan, For decades Magnox success was measured in terawatt hours of electricity, where higher was better. Now the focus is on decommissioning and waste management, where the target is zero. Retrieving and packing wastes from vaults, draining down cooling ponds, shipping metals for recycling all contributes towards reducing hazards and achieving C&M entry. Therefore, a series of measures tracking decommissioning work has been developed and is reported monthly to help monitor performance. The next page shows how Magnox has performed against waste targets during 2013/14, including the volume of waste disposed of and shipped from sites. In addition, to track progress in the longer term, six further measures have been developed covering the main decommissioning and hazard reduction programmes: disposed of March Waste Metrics Dashboard

13 Waste Metrics March Waste Metrics Dashboard Magnox is the management and operations contractor responsible for ten nuclear sites and one hydroelectric plant in the UK working for the sites' owner, the Nuclear Decommissioning Authority (NDA). Magnox Sites Most Favoured Option Magnox waste LLW destinations by hierarchy (m 3 ) FY (2013/ Year to Date) LLW Re-classified as Out of Scope LLW Recycling (Metal) LLW Re-classified as LALLW/VLLW LLW Disposed by Incineration LLW Volume Reduced by Super-Compaction LLWR Most Favoured Option Magnox waste ILW destinations by hierarchy (m 3 ) FY (2013/ Year to Date) ILW Treatment Dissolution (Volume Reduction) ILW sorted to LLW ILW Decay Stored ILW Treatment (MiniStores) ILW Treatment (Encapsulation) ILW Retrieved 1. Berkeley 2. Bradwell 3. Chapelcross 4. Dungeness A 5. Hinkley Point A 6. Hunterston A 7. Oldbury 6 8. Sizewell A 9. Trawsfynydd 10. Wylfa 11. Maentwrog Least Favoured Option Least Favoured Option m 3 m 3 3 Magnox hierarchy for non-rad destinations (te) FY (2013/ Year to Date) Magnox non-rad waste disposition by type (te) FY (2013/ Year to Date) Avoidance/Reduction Recycle Hazardous Landfill/Disposal Inert Metals 10 9 Reuse of Equipment Recycle/Reuse Inert Recycle Non hazardous Incineration Energy Recovery Incineration Sewage WEEE Sewage Non hazardous Others Asbestos Hazardous Waste (Excl Asbestos) 11 Most Favoured Option Least Favoured Option 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 te 0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 11,000 te 31/03/ Period 60

14 Waste Programme Metrics Pond water volume drain 2011/2015 Asbestos volume 2011/2015 Plant and Structures deplant/demolition/disposal 2011/2015 Volume of Water in the Ponds LTP10 Volume of Water in the Ponds MODP Volume of Water in the Ponds Actual Current Baseline Volume of Asbestos remaining on plant LTP10 Volume of Asbestos remaining on plant MODP Volume of Asbestos remaining on site Actual Predicted Plant and Structures demolished/disposed LTP10 Predicted Plant and Structures demolished/disposed MODP incorporating DNA revisions current Baseline PS3 Plant and Structures demolished/disposed Actual m 3 m 3 m 3 (000s) 25,000 18,000 1,000 16, ,000 14,000 12, A 15,000 A 10, ,000 8,000 A 800 6, ,000 4,000 2, In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 Achievements 2013/14 A Hunterston A: 1808m 3 Pond drain year to date (5686m 3 total drained to date) Hinkley Point A: 1269m 3 Pond drain year to date (3812m 3 total drained to date) Hinkley Point A: No Pond discharge between P58 to P60 due to planned work stabilising the pond walls in R2 Achievements 2013/14 A Chapelcross: Reactor Phase 2 continues with 103 tonnes of Asbestos being disposed of as VLLW Dungeness: South side Turbine hall Asbestos removal commenced with approximately 70 tonnes of Abestos removed from site to date Achievements 2013/14 A Dungeness: Several buildings have now been demolished from the South Side of the site Chapelcross: The demolition of the Graphite Handling Facility was completed in March Data is currently under review 31/03/ Period 60

15 Waste Programme Metrics FED ILW volume dissolution 2011/2015 Wet ILW processing 2011/2015 Solid ILW processing 2011/2015 FED in vaults less retrieved and dissolved LTP10 FED in vaults less retrieved and dissolved MODP (P33 Baseline) FED in vaults less retrieved and dissolved Actual FED in vaults less retrieved Actual FED in vaults less retrieved and dissolved MODP incorporating BOP2 revisions (current baseline P46) Volume of Wet ILW in Tanks/Vaults LTP10 Volume of Wet ILW in Tanks/Vaults MODP Volume of Wet ILW in Tanks/Vaults less retrieved and processed/conditioned Actual Volume of Wet ILW in Tanks/Vaults less retrieved Actual Volume of Solid ILW in Situ less retrieved and processed LTP10 Volume of Solid ILW in Situ less retrieved and processed MODP Volume of Solid ILW in Situ less retrieved and processed/conditioned Actual Volume of Solid ILW in Situ less retrieved Actual m 3 m 3 m 3 2,000 1,350 5,500 1,300 1,900 B 1,250 5,000 A 1,800 1,200 B 1,150 4,500 1,700 A 1,100 A 4,000 1,600 1,050 1,500 1, ,500 1, ,000 In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 In Situ total 2011 P26 P28 P30 P32 P34 P36 P38 P40 P42 P44 P46 P48 P50 P52 P54 P56 P58 P60 Comprehensive spending review periods P62 P64 P66 P68 P70 P72 Achievements Achievements Achievements 2013/ / /14 A Bradwell: A total of 1258 drums of FED has now been A Bradwell: 43.29m 3 of Wet ILW has been retrieved and A Bradwell: 132 drums of Gravel, assuming a loading retrieved from Vaults 1A, 1B, 7A, 7B, 8A & 8B m 3 currently awaiting conditioning. 5m 3 of Sludge of 0.2m 3 per drum has now been retrieved from Vaults Assuming 0.2m 3 per drum gives a total of 251.6m 3 of has been conditioned from Vault 6A tank 61V and stored 1A, 1B, 7A, 7B and 8A FED retrieved to date in the ISF B 255 drums of FED has now been shipped to DNA Assuming a loading volume of 0.2m 3 this amounts to 51m 3. Berkeley: 27.1m 3 of Sludge and Resin has been retrieved from SST1 & SRST1 into 14 DCIC's awaiting conditioning All 255 drums (20448 kg) have been loaded into the Dissolution Plant with a current discharge of 16304kg Hinkley: 63.5m 3 has been retrieved from ST1, ST2 & ST3 into DCIC's awaiting conditioning B Trawsfynydd: 17.32m 3 of Ion Exchange Resin retrieved and conditioned from the Resin Vault 31/03/ Period 60

16 Berkeley Centre Berkeley Gloucestershire GL13 9PB

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