Magnox Sustainability Plan....an on-going commitment to embedding and improving sustainability across our business.

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1 Magnox Sustainability Plan...an on-going commitment to embedding and improving sustainability across our business.

2 Introduction Magnox Limited manages and operates ten nuclear licensed sites and one hydroelectric power station on behalf of the Nuclear Decommissioning Authority (NDA). These sites are at varying stages of operation and decommissioning, each with its own range of challenges from optimising generation of electricity to managing decommissioning. 1

3 NDA Mission Deliver safe, sustainable and publicly acceptable solutions to the challenge of nuclear clean-up and waste management. This means never compromising on safety, security, taking full account of our social and environmental responsibilities, always seeking value for money for the tax payer and actively engaging with stakeholders. Our overall objective is to ensure that the NDA delivers its mission at the Magnox sites. We achieve this through the way we develop and implement our strategies for managing our business and delivering the Magnox Optimised Decommissioning Programme (MODP). These strategies are aimed at achieving sustainable outcomes in the broadest sense within the business environment in which we operate. For Magnox, sustainability is about having the capability to endure as a responsible and efficient business that balances the delivery of our stated mission through the Magnox Optimised Decommissioning Programme (MODP) with the needs of the environment, stakeholders, customers, staff and the requirements of UK PLC. Definitions Sustainable: To be able to maintain at a certain level. To uphold or defend. Sustainability is the concept that business and community well-being cannot be improved using measures that destroy the environment. Sustainable development is development which meets the needs of the present without comprising the ability of future generations to meet their own needs (United Nations General Assembly Resolution 42/18) 2

4 Magnox Sustainability Objectives We have set the following objectives as the key focus areas to ensure that we operate and decommission the Magnox nuclear sites in the most sustainable way: 1. Minimise the risks left for future generations to manage. 2. Utilise resources efficiently. 3. Strive to leave a positive legacy for the communities we operate in. 4. Support our workforce throughout the site programme changes. 5. Work with our suppliers to share the delivery of our goals. 6. Pioneer, innovate and transform our ways of working to maximise business efficiency. 3

5 Magnox Sustainability Plan We will raise the visibility of our existing activities related to sustainability through this sustainability plan. This plan: 1. Brings together in one place the many strands of sustainability work that are already embedded within our corporate arrangements. 2. Highlights our sustainability objectives. 3. Establishes sustainability governance by clearly communicating accountability. 4. Improves the measurement of our performance. 5. Enables us to better report our progress and to report publically. Whilst the Managing Director has ultimate responsibility for sustainability, accountability lies with the Directors in four key areas: community, environment, workforce, and business delivery. The Communications Director takes the lead on community related projects; the EHSS&Q Director drives improvements in environmental performance; the Human Resources Director ensures that we are a competent organisation and provides the framework for the support of our workforce, which is particularly important during periods of significant transition; and the Commercial Director in conjunction with the Chief Nuclear Officer (Fuelled sites), Chief Operating Officer Decommissioning Sites (England), Chief Operating Officer Decommissioning Sites (Wales / Scotland) and Strategic Programmes Director provide the challenge and control to ensure we deliver our contract to the NDA effectively. 4

6 This Plan brings together the activities that improve our sustainability performance. The diagram below illustrates how this plan is embedded across the business. IWS Action Plan Commercial Development Plan Magnox 4 P Plan Over the next year we will raise the visibility of our existing activities related to sustainability. This, our Sustainability Plan, contributes to that process and we will publically report progress against our plan once a year. Sustainability Plan L&D Strategy & Plan Magnox Optimised Decommissioning Programme For further information visit our website: magnoxsites.co.uk Magnox Socio- Economic Development Plan Integrated Decommissioning & Waste Management Strategy 5

7 The following table provides more details about our sustainability objectives: Sustainability Objective 1. Minimise the risks left for future generations to manage In the context of our business The hazards we manage and the wastes generated present different challenges due to their radiological, physical, chemical and biological characteristics. For some wastes, treatment options are limited. However, we will strive to optimise the application of the waste hierarchy and continue to sustain the high levels of recovery, reuse and recycling that we have achieved over the last few years. In doing so, we will divert waste from disposal either at landfill or the Low Level Waste Repository (LLWR) whenever we can. At the completion of the Care and Maintenance (C&M) Preparation phase, each site will be left passively safe as far as reasonably practicable. The C&M hub will manage all ten sites from entry into C&M through to Final Site Clearance to ensure that they remain safe and secure. 2. Utilise resources efficiently The consumption profiles of resources such as water and energy vary through the different stages of a site s lifecycle. For example, energy consumption will increase as waste is processed to reduce its hazard and/or size, which provides an overall environmental benefit. Consequently, it is difficult to set any meaningful absolute reduction targets. Instead, we seek to optimise the use of resources and we seek out opportunities to reduce consumption. 3. Strive to leave a positive legacy for the communities we operate in 4. Support our workforce throughout the site programme changes 5. Work with our suppliers to share the delivery of our goals 6. Pioneer, innovate and transform our ways of working to maximise business efficiency We recognise that as sites enter the Care & Maintenance phase, the number of people we employ at our sites will reduce significantly. This could affect the economic wellbeing of those communities in which we operate, particularly those which may already be facing socio-economic challenges. We will continue to take a pro-active approach to help such communities. The welfare of our workforce is critical to our business as is developing, maintaining and retaining the skills we need. We have (and will continue to develop) plans and processes to achieve these objectives - for example, by implementing programmes to re-skill the workforce as the sites go through their lifecycle. By continuing to work with strategic partners and Small to Medium sized Enterprises (SMEs) we will be looking for opportunities to make our commercial arrangements more efficient, effective, and sustainable. Year on year, we have been set targets to improve cost and performance by the NDA. We have reviewed our strategy to improve the way we decommission and have developed the Magnox Optimised Decommissioning Plan (MODP), which includes a more effective programmisation approach to decommissioning. Through this we will realise significant savings and early hazard reduction. 6

8 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 1. Minimise the risks left for future generations to manage Review the Environmental Effects Register to identify hazards/risks for reduction. Lower risk to the environment - no harm resulting from events. Identify and manage risks arising from assets and infrastructure. Registers reviewed. Action Plans in place Q2. Deliver identified actions Repair, replacement or removal of buried drains prioritised and funded accordingly. Q1 Q2 Q3 & Q4 No events leading to significant environmental harm. Achieve target dates for actions as set in drainage Mandatory Assessment. Chief Operating Officers Engineering Director Magnox 4 P Plan Magnox 4 P Plan Reduced risk of events leading to environmental harm and/or loss of stakeholder confidence. Increase application of the waste hierarchy to LLW to help reduce waste disposed of to Low Level Waste Repository (LLWR). % of Asset Management Programme completed. Complete risk assessments of hazardous chemical containment facilities. Divert or treat metallic waste. Divert or treat combustible waste. >95% YE Q4 761 tonnes 1176M 3 LLW Strategy & Delivery Manager Waste & Decommissioning Strategy Programme To help optimise LLWR disposal capacity. Divert Very LLW (VLLW) and Low Activity LLW (LALLW). 1900M 3 7

9 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 2. Utilise resources efficiently Produce and use plan to continue to target areas of most impact energy, water and non-radioactive waste. Plans produced. Sites delivering to their energy efficiency and leak management plans. Q1 Progress report quarterly EHSS&Q Director and Waste Director Magnox 4 P Plan Optimise resource efficiency & maintain positive environmental performance. Maintain high environmental index performance. >90% YE Maximise the use of existing assets and progress with the treatment of Fuel Element Debris (FED). Facilitating the accelerated entry into Care & Maintenance of Bradwell site. Achieve significant volume reduction in the processing of FED. Maximised use of existing FED dissolution plant at Dungeness by processing some of Bradwell FED at Dungeness A Site. 90% 16 Te FED Programme Director IWS Action Plan (6) Optimise the application of the waste hierarchy. Enable better management from cradle to grave of all waste. Aim to maximise diversion of nonradioactive waste from landfill. Inventory data for all waste imported into the company emwaste Tracking Tool. 80% All waste data imported Waste Operations Manager Waste Operations Programme

10 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 3. Strive to leave a positive legacy in the communities in which we operate Develop socio-economic partnership model around our sites. Improving local business and local community opportunities. Romney Marsh Partnership Group developed to deliver the Marsh Million project. Partnership working at Bradwell established. Year one outputs achieved. Partnership group established Head of Communications Magnox Socio- Economic Development Plan Partnership working at Hunterston established. Partnership group established Effectively manage socio-economic funding on behalf of the NDA. Empowering local communities. Applications for funding managed in line with the socio-economic process and development plan. Positive press coverage related to projects Head of Communications Magnox Socio- Economic Development Plan Process all applications in a timely manner: o < 10k projects to go live o > 10k< 100k o > 100k within 2 months within 6 months within 1 year 9

11 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 4. Support our workforce throughout the site programme changes Manage transition skills requirements Being a competent sustainable organisation. Develop and implement training standards and programmes to support the company, NDA and supply chain in being sustainable competent organisations. Strategic support to national nuclear skills development. Develop relationships with national transfer partners, NDA and sites to optimise re-deployment opportunities. Support employees in transition by providing advice and training. Undertake reskilling of staff in transition. Develop apprenticeship programme to pump and prime supply chain. Support NDA Nuclear Graduate Programme & Resourcing Group in identifying skill shortages and develop solutions. Take a pro-active role in developing national standards and qualifications for use across the nuclear industry via National Skills Academy Nuclear (NSAN) and Cogent Sector Skills Council. Roll out e-academy to deliver more cost effective training and reduce environmental impact from travelling. Relationships developed. Progress to plan. Defined no. of staff 17 apprentices 10 Nuclear Graduates Input delivered to standards and qualifications. e-academy in place. Transition Director L&D Talent Manager L&D Improvement Plan, Transition Plan L&D Strategy & Plan Train staff working in areas that can have potentially significant environmental impact. Improved environmental performance. Review and issue the Core Environmental Training Standard. Review how best to train procurement staff on sustainability including how they can make an impact with the projects they manage (e.g. CIPS or equivalent). Standard issued. Review completed. HoPE&W L&D Manager HoPE&W Environment Improvement Plan 10

12 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 5. Work with our suppliers to share delivery of our goals Deliver Small to Medium Size Companies (SME) Growth Agenda. Target to sustain 20% of supply chain spend awarded to SMEs, directly and indirectly through the supply chain. 20% of supply chain spend to SMEs Supply Chain Development Manager Commercial Development Plan Supporting sustainable procurement Procurement plan and strategic programme supply chain map updated with supply chain details of companies bidding and companies awarded contracts and available on Magnox website. Plan and map updated. Incorporate sustainability issues into the selection of pension fund investments. Sustainability issues incorporated into investment decisions. Regular meetings/briefings undertaken with suppliers and business groups to help facilitate potential business opportunities. Socially Responsible Investment statements reviewed for all potential new investment managers, prior to appointment. Briefings held Statements reviewed. Head of Pensions Trustee Board & Trustee Board Statement of Investment Principles Improve the effectiveness of the delivery of contracts to enable greater efficiency and overall sustainable business outcomes. Reduced costs by efficient delivery of programmes/contracts along with reduced schedule. Improve Sub Contract Management. Benefit from Lead and Learn: Plan for improving sub-contract management developed. Pro-active use of CEMAR management information tool. Company staff/sub-contractors briefed on use of NEC3 contract methodology. Submit supply chain report to NDA on contract performance. Plan available. CEMAR fully utilised. Briefing completed. Report submitted. Head of Commercial Development Commercial Development Plan 11

13 Objective & Expected Outcome Activities Target Who Integrated Plan Sources Expected Sustainability Benefits Socio Econ Env 6. Pioneer, innovate and transform our ways of working to maximise business benefit Implement programmisation according to Life Time Plan (LTP) Deliver decommissioning and hazard reduction in an effective manner to minimise lifetime costs. Progress according to LTP: Ponds decommissioning. Fuel Element Debris (FED) treatment. Intermediate Level Waste (ILW) treatment Plant and Structures decommissioning. LTP and LC35 Key Milestones Strategic Programmes Director Magnox Optimised Decommissioning Programme Optimise the management of Low Level Waste (LLW). To embed the UK low level waste strategy within Magnox as part of a national waste programme. Delivery of the Joint Low Level Waste Management Plan (JWMP). Plan delivered Waste Programme Director IWS Action Plan (10) Undertake benchmarking to share learning and identify good practice. Identifying ways to improve. Shared learning undertaken to potentially help improve performance and reduce impact at our own sites and others. Learning identified and communicated. HoPE&W HoPE&W Environment Improvement Plan 12

14 Magnox Sustainability Indicators These measures have been chosen as appropriate indicators of our performance in achieving our six Sustainability Objectives, and to provide an overall health check of trends in these key areas. Sustainability Objective KPI Source Minimise the risks left for future generations to manage Utilise resources efficiently Strive to leave a positive legacy for the communities we operate in 0 non-compliances>ccs and CICS 4 1. >95% of Asset Management Programme completed. Divert >3000M 3 of Low Level Waste from Low Level Waste Repositry (LLWR) >90% score for Magnox as a whole against the Environmental Index (includes energy & water consumption, and CO 2 emissions). >80% of non-radiological waste diverted from landfill. >4 score on the NDA Environmental Sustainability Criterion 2. Process funding application requests for projects: > 10k within 2 months > 10k< 100k within 6 months 4 P Plan 4 P Plan Waste & Decommissioning Strategy Programme The Magnox Environmental Index 3 Sustainability Plan NDA Environmental Sustainability Criterion 8 Sustainability Plan > 100k within 1 year 13

15 Sustainability Objective KPI Source Support our workforce throughout the site programme changes Work with our suppliers to share the delivery of our goals >95% work place inspections undertaken to programme 4. 90% of staff trained to plan 5. Total Reportable Injuries and Days Away Case Rates Monitored 20% of supply chain funding awarded to SMEs Contract strategies approved by plan date. 4 P Plan 4 P Plan Conventional Safety Dashboard Sustainability Plan Commercial Performance Report to the NDA Pioneer, innovate and transform our ways of working to maximise business efficiency Framework agreement statement published. Meet NDA Operational Plan Targets 6. Meet CPI of 1.03 for Magnox as a whole 7. Supply chain management tracking tool NDA Operational Plan NDA Target 14

16 Notes on the Indicators 1. Compliance Classification System (CCS) and Compliance Incident Classification System (CICS) are Environment Agency developed scoring systems to assess potential significance with 1 indicating major through to 4 for minor/trivial impacts. CCS relates to non-compliances with the Environmental Permit that also have potential impacts. CICS assess potential impacts from an incident. 2. The Nuclear Decommissioning Authority (NDA) assesses our performance against many targets and plans; one of these is the NDA Criterion 8 on Environmental Sustainability (ES). The assessment is against a number of attributes from sustainability leadership, how ES is embedded into the business processes, how resources are managed, ES metrics and alignment of metrics on ES to NDA metrics and Government Targets. The score ranges from 1-5, 1 non-compliant, 4 - supplier meets NDA expectations and 5 indicates an exceptional supplier. 3. The Magnox Environmental Index assesses a range of environmental issues including performance against energy efficiency plans and monitors water use against baseline. 4. This indicator reflects our priority for Managers and Team Leaders to understand their accountability for the safety of people they put to work and show leadership by undertaking workplace inspections to engage with people, to re-enforce standards and undertake behavioural safety observations. 5. Our commitment to training our staff supports our strategic objective to ensure that we are a competent organisation targets have been set by the NDA against key programme delivery activities and these have been translated into 85 performance based indicator milestones. 7. Cost Performance Indicator (CPI) is a cost reduction target set by the NDA year on year. This year s target is 1.03 which means we have to achieve a 3% cost saving. This will be challenging on top of savings already achieved. For further information, please contact us: magnox.communications@magnoxsites.com 15