Magnox Limited – Integrated Decommissioning and Waste Management Strategy

May 2016 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

2 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Executive Summary

Under contract with the NDA, Magnox is The near-term company objective is to deliver responsible for delivering the clean-up and the Magnox sites into a safe and secure restoration of the 12 Magnox sites in line with interim state. This will involve reducing the NDA mission. hazards on site by: Site decommissioning and remediation is the  Transfer of all spent fuel to off-site primary focus of the company aiming to facilities for treatment and storage; achieve the site end state to “make the site  Transfer of nuclear materials to off- suitable for the next planned use”. The waste site facilities for management; management strategy supports / enables its delivery.  Dismantling reactors or preparing reactor buildings for safe storage; The decommissioning strategy involves systematic and progressive hazard reduction  Decommissioning redundant facilities; and takes advantage where possible of the process of natural radioactive decay to reduce  Retrieving, treating, packaging and levels of radioactivity and hence risk to people disposal/storage of waste; and. and the environment.  Managing contaminated land. The decommissioning strategy for each site includes one or more periods when the plant/ The Magnox integrated decommissioning and facility is purposely kept in a state of “care waste management strategy has been and maintenance” or “quiescence” as part of developed to ensure that activities are carried the programme for achieving the site end out in a way that protects people, plant and state. Therefore, the sites will work towards the environment; complies with Government interim states in the near-term. Hazards will policies; and provides value for money. be removed to ensure risks remain tolerable and As Low As Reasonably Practicable (ALARP) at all times, including during any period of quiescence.

This document is submitted by Magnox Limited to the NDA as a statement of company strategy. Implementation of the company strategy on a site is subject to regulatory permissioning; it is dependent on completion of all necessary underpinning and the granting of appropriate authorisations, licenses, permits or approvals.

3 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Contents

1 Introduction ...... 5 1.1 Background ...... 5 1.2 Purpose ...... 5 1.3 Scope ...... 5 2 Objectives and Aims ...... 6 2.1 Overarching Objectives ...... 6 2.2 Near-term Objectives...... 6 2.3 Waste Hierarchy ...... 7 2.4 Interactions with Other Policies, Strategies and Plans ...... 7 3 Decommissioning Strategy ...... 8 3.1 Site End States ...... 8 3.2 Decommissioning Strategy Phases ...... 8 3.3 Decommissioning Strategy ...... 10 4 Summary of Waste Inventory ...... 11 5 Waste Management Strategy ...... 12 5.1 Radioactive Waste ...... 12 5.2 Non-Radioactive Waste ...... 15 5.3 Aqueous and Gaseous Discharges ...... 17 6 Strategy Implementation ...... 19 6.1 Implementation during Defuelling ...... 19 6.2 Implementation prior to the Interim State ...... 19 6.3 Implementation during the Interim State ...... 19 7 Assumptions and Risks ...... 20 7.1 Assumptions ...... 20 7.2 Risks ...... 20 8 Monitoring and Evaluation ...... 22 9 Communication and Consultation ...... 23 9.1 Regulatory and Stakeholder Input and Consultation ...... 23 9.2 Communication ...... 23 9.3 Accessibility ...... 23 10 Definitions ...... 24 Site Specific Appendices ...... 25

4 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

1 Introduction 1.1 Background 1.3 Scope The Nuclear Decommissioning Authority The strategies contained within this document (NDA) is a strategic authority established in apply to all the company’s nuclear licensed 2005 under the Energy Act 2004. It is sites (and associated land-holdings), and all responsible for decommissioning and clean- their wastes, ie radioactive and non- up of civil nuclear facilities and delivers its radioactive, solid, aqueous and gaseous strategy through licensed operators known as wastes. The strategy covers the site lifecycle, site licence companies. focusing on the post-defuelling phases. Magnox Ltd1, owned by Cavendish Fluor This document describes the company Partnership, is the management and decommissioning and waste management operations contractor responsible for 12 strategy only. It does not provide tactical nuclear sites (see Figure 1) and one detail on the methods that will be deployed to hydroelectric plant in the UK working for the deliver the strategies at the sites; these are sites' owner, the NDA. generally determined via a programme approach to deliver common solutions across Following the change in Parent Body the company. Organisation (PBO) in September 2014, Magnox has reviewed the decommissioning Site specific decommissioning and radioactive and waste management strategy. The revised waste management strategy is described in strategy is presented here. the site appendices. Implementation of the company strategy on a site is subject to 1.2 Purpose regulatory permissioning; it is dependent on completion of all necessary underpinning and The purpose of this document is to define the the granting of appropriate authorisations, company decommissioning and waste licenses, permits or approvals. management strategy for the 12 Magnox nuclear licensed sites. Figure 1: Magnox sites. The company integrated decommissioning and waste management strategy is developed in accordance with the requirements of current legislation, government policies, regulatory requirements, the NDA strategy and company environment, health & safety policy.

Dragon reactor at Winfrith

1. Berkeley 7. Hunterston A 1 Formerly two separate site licence companies: 2. Bradwell 8. Oldbury Magnox Ltd and Research Sites Restoration Ltd. 3. Chapelcross 9. Sizewell A 4. Dungeness A 10. Trawsfynydd 5. Harwell 11. Winfrith 6. Hinkley Point A 12. Wylfa 5

Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

2 Objectives and Aims 2.1 Overarching Objectives 2.2 Near-term Objectives Magnox is responsible for delivering the The near-term company objective is to deliver clean-up and restoration of the 12 Magnox the Magnox sites into a safe and secure state. sites in line with the NDA mission. This will involve reducing hazards on site by:

Site decommissioning and remediation is the  Transfer of all spent fuel to off-site primary focus of the company. The waste facilities for treatment and storage; management strategy supports / enables its  Transfer of other nuclear materials to delivery. off-site facilities for management; The Magnox strategy is driven by the NDA’s  Dismantling reactors or preparing objectives, which are set out in the NDA reactor buildings for safe storage; Strategy to support their mission. The relevant NDA objectives are identified  Decommissioning redundant facilities; throughout this document.  Retrieving, treating, packaging and On behalf of the NDA, Magnox manage the disposal/storage of waste; and sites through their lifecycles, overseeing all  Managing contaminated land. aspects decommissioning. Following the change in PBO and merger of The Magnox integrated decommissioning and site licence companies, a key short-term waste management strategy has been objective is to establish a single integrated developed to ensure that activities are carried strategy for the 12 Magnox sites. This will be out in a way that protects people, plant and achieved through adopting a programme the environment; complies with Government approach. policies; and provides value for money.

Figure 2: waste hierarchy.

 Avoid excavation of material Avoid / reduce  Use of local recycling facilities for out-of- which might become waste scope wastes by in-situ management 1 3  Use of the LLWR framework and metal  Segregation of waste at Re-use / preparing recycling route workface by: waste category, for re-use physical, chemical and radiological properties to reduce the volumes of higher Recycling  Use of commercial “waste-to- activity waste energy” combined heat and Energy recovery 4 power generation as disposal  Consolidated stores reducing route for out-of-scope build and maintenance combustible waste resources Disposal  Decontamination to enable reuse/recycling or  Re-use out-of-scope building  Use of the LLWR framework management as a lower rubble and soil from incineration and VLLW route category of waste decommissioning to backfill 2 5  Maximising packaging voids efficiency by appropriate  Re-profile land with material waste package selection from adjacent areas  Treatment to reduce waste  Reuse of decommissioning disposal volumes, such as tools and equipment within compaction, size reduction or and between sites dissolution

6 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

2.3 Waste Hierarchy The waste hierarchy (see Figure 2) provides a developed to be compliant with UK key input to decisions regarding the legislation; be consistent with government management of waste. Prevention and policy, NDA strategy and company policy; to minimisation of waste generated is preferable take due account of regulatory and in the first instant. Where wastes are generated, reuse and recycling are preferred stakeholder views; and to take due account of to disposal. regulatory and industry guidance. The application of the waste hierarch requires Figure 3 illustrates the integration of the a balance of priorities including protection of strategy within this document with health, safety, security and the environment, government policy; NDA strategy; site value for money, affordability and technical underpinning and justification; and the maturity. Magnox applies the waste hierarchy reporting of progress on delivery. to the management of all waste. Implementation of strategies at sites is 2.4 Interactions with Other Policies, controlled via company management Strategies and Plans arrangements. Site specific documents will The Magnox integrated decommissioning and detail and justify the implementation of the waste management strategy has been strategy at each site.

Figure 3: interactions with other strategies and plans.

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n International standards and guidance (e.g. IAEA) I EU Directives

UK and devolved Government Policy y c i l o

P Non-Rad Waste Managing Radioactive Scottish HAW Welsh HAW UK Policy for Management Command 2919 Policy of Solid LLW Waste Safely Policy Policy

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g UK Nuclear e t Strategies Industry LLW UK Strategy for a

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7 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

3 Decommissioning Strategy

NDA Objective: Harwell and Winfrith sites will achieve their site end state on shorter timescales compared  To decommission and remediate our to the other sites. Therefore, their site end designated sites, and release them for states are more defined. The assumed next other uses. uses are: a science and technology park for  To deliver Site End States as soon as Harwell; and natural heathland for Winfrith. reasonably practicable with a The Magnox sites will work towards achieving progressive reduction of risk and their site end states over their lifecycle. The hazard. work will be carried out over a series of  To ensure that land quality is managed strategy phases, as described in the to protect people and the Section 3.2. environment. 3.2 Decommissioning Strategy Phases  To define credible objectives for the restoration of each site (or part of a The decommissioning strategy involves site). systematic and progressive hazard reduction and takes advantage where possible of the  To optimise the re-use of NDA sites. process of natural radioactive decay to reduce levels of radioactivity and hence risk to people 3.1 Site End States and the environment. A site end state describes the condition to Harwell and Winfrith are adopting an early which a site needs to be restored. The reactor dismantling strategy whereas for the physical end state of the Magnox sites will be remaining Magnox Sites, a deferred reactor to: dismantling strategy is being adopted. Deferring reactor dismantling on these sites “make the site suitable for the next allows benefits to be gained from radioactive planned use” decay and manages existing constraints on Current working assumptions to achieve the the availability of waste routes. site end states are: In both cases a staged approach to the  All buildings will be removed from the decommissioning and restoration of the site is site. being undertaken.  Some subsurface structures will The decommissioning strategy for each site remain on the site (ie brownfield site). includes one or more periods when the plant/ facility is purposely kept in a state of “care  Nuclear site licences and EPR10 and maintenance (C&M)” or “quiescence” as permits / RSA93 authorisations part of the programme for achieving the site surrendered. end state (see Figure 4). It is the preference of the NDA to retain flexible site end state definitions until The sites will work towards interim states in planning commences for the final stages of the near-term which are further defined restoration. The definitions will be reviewed, within this document. Hazards will be in consultation with stakeholders, as removed to ensure risks remain tolerable and decommissioning progresses. As Low As Reasonably Practicable (ALARP) at all times, including during any period of quiescence.

8 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 4: Decommissioning strategy phases.

Site Interim State Site End State Reactor Care & Final Site Dismantling & Maintenance Clearance Partial Delicensing

 Reactor dismantling  Other facilities  Dispatch of ILW  Waste processing & inspection & packages dispatch maintenance  Demolition of ILW Harwell  ILW packaging  ILW package Stores  ILW Store monitoring &  Land remediation construction inspection  Surrender nuclear  Redundant facility  Land monitoring site licence & demolition, land EPR10 permit remediation & delicensing (outside B462)  Prepare B462 for C&M

Site Interim End State Site End State Reactor Dismantling Quiescence & Site Restoration Winfrith  Reactor dismantling  Radioactive decay  Surrender nuclear  Redundant facility  Land monitoring site licence & demolition & land EPR10 permit remediation  Waste processing & dispatch  ILW packaging

Site Interim State Site End State Care & Care & Final Site Maintenance Maintenance Clearance Preparations Berkeley Bradwell  Reactor safestore  Safestore  Reactor Dungeness A preparations inspection & dismantling Hinkley Point A  Waste processing & maintenance  Demolition of all Oldbury dispatch  Other facilities other facilities Sizewell A  ILW packaging inspection &  Waste processing Trawsfynydd  ILW Store maintenance & dispatch Wylfa construction (as  ILW package  Land remediation required) monitoring &  Surrender nuclear  Redundant facility inspection site licence & demolition / make  Dispatch of ILW EPR10 permit safe packages  Land management  Demolition of ILW Store as required  Land monitoring

Site Interim State Site End State Reactor Care & Care & Dismantling Long-Term Final Site Maintenance Maintenance & Site Storage of ILW Clearance Preparations Restoration  Reactor safestore  Safestore  Reactor  ILW package  Dispatch of ILW preparations inspection & dismantling monitoring & packages  Waste processing & maintenance  Demolition of all inspection  Demolition of ILW Chapelcross dispatch  Other facilities other facilities  Replacement ILW Stores Hunterston A  ILW packaging inspection &  Waste processing Store construction  Surrender nuclear  ILW Store maintenance & dispatch site licence & construction  ILW package  ILW packaging RSA93  Redundant facility monitoring &  New ILW Store authorisation demolition / make inspection construction safe  Land monitoring  Land remediation  Land management

9 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

3.3 Decommissioning Strategy Site decommissioning and remediation is the  Adopting simpler decommissioning primary focus of the company. The waste techniques: performing pond management strategy supports/enables its furniture removal and waste size reduction under water (using divers) delivery. and use of high pressure water The near-term decommissioning strategy decontamination methods. involves preparing the Magnox sites for their  Managing/monitoring contaminated interim state / interim end state. land in-situ in a manner that avoids 3.3.1 Strategy the need for intervention during quiescence. The Magnox decommissioning strategy is to dismantle the reactors at Harwell and  Avoid / reduce importing clean Winfrith and prepare the other sites reactors materials for land restoration by for safe storage (where dismantling will take reusing inert wastes from place 85 years after shut-down). Over the decommissioning for backfilling lifecycle strategy phases, wastes will be voidage and managing any remaining retrieved and managed; facilities voids during quiescence. decommissioned; and the land restored to Magnox are working with the regulators and enable next planned use. NDA to establish optimised site end states Key aspects to the Magnox decommissioning which may include in-situ disposal of strategy include: redundant contaminated structures. Magnox are also working with NDA to explore  The removal, as far as practicable, of the opportunity to optimise the timing of all higher hazards prior to entry of interim states. This will include the reactor dismantling. removal of accessible asbestos. The sites will adopt this generic decommissioning strategy as appropriate (see  Demolition of redundant (mainly non- Appendices). radioactive) plant and buildings prior to interim state entry. 3.3.2 Challenges  Early dismantling of reactors at Key challenges associated with the strategy Harwell and Winfrith using available going forward include: technologies.  Demonstrating optimised interim  For Magnox reactor sites, optimising entry states. reactor safestore preparations: boilers left in-situ; adopting risk-based  Developing arrangements for asset deplanting; and maximising the life of management during quiescence. the safestore cladding.  Developing processes and systems  Optimising the timing of that safeguard the necessary decontamination and demolition of knowledge about the site and facilities redundant contaminated facilities (ie during the quiescent period. fuel ponds and waste vaults), taking advantage of radioactive decay to minimise lifecycle safety, environmental and cost impacts.

10 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

4 Summary of Waste Inventory Definitions of the different waste types can be caesium-137 and tritium for aqueous found in section 9. For the purpose of this discharges, and tritium and carbon-14 document they are broadly categorised as: for gaseous discharges. Non- radioactive discharges are also  Radioactive Waste – any material controlled by limits where applicable that is either radioactive itself or is under the relevant regulation. contaminated by radioactivity, for which no further use is envisaged. Characterisation of waste to determine its This includes a wide variety of volume, physical, chemical and material, ranging from wastes that radiological properties is required to can be decontaminated and recycled produce a reliable waste inventory and is to items that need remote handling an integral part of developing a waste and heavy shielding to be managed strategy. The company has developed a safely. The radioactive wastes waste characterisation process to ensure considered within this document are a consistent approach is adopted to waste under the categories: nuclear characterisation. materials; Intermediate Level Waste Figure 5 shows the volume of waste to be (ILW); Low Level Waste (LLW); and managed across the 12 sites. The total Very Low Level Waste (VLLW). amount of waste to be managed across  Non-Radioactive Waste – the non- the sites over all phases is ~2.5 million m3. radioactive wastes considered within More detail about site waste arisings is this document are under the provided in the UK radioactive waste categories: hazardous (referenced to inventory. as special waste in Scotland); and non-hazardous (which includes inert, 2% eg concrete and rubble).

 Discharges – aqueous and gaseous 20% discharges are regulated under EPR10/RSA93. The principal isotopes 48% 3% of interest are dominated by 27% Figure 5: total volume of raw waste to be managed.

Now to ~2030

~2030 to ~2070 ILW

LLW (incl. VLLW)

~2070 to ~2100 Hazardous

Non-hazardous

~2100 to ~2300 Inert

0 500,000 1,000,000 1,500,000 Volume of raw waste (m3)

11 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

5 Waste Management Strategy 5.1 Radioactive Waste Key aspects to the Magnox radioactive waste NDA Objective: strategy include:  To ensure safe, secure and cost-  Appropriate consideration of the effective lifecycle management of our waste hierarchy and use of available nuclear materials. routes to divert waste from disposal  To manage radioactive waste and (by burial) as far as reasonably dispose of it where possible, or place it practicable. in safe, secure and suitable storage,  Treatment (ie dissolution, compaction ensuring the delivery of UK and or decontamination) to reduce Devolved Administrations policies. volumes for disposal as radioactive waste. The following types of radioactive waste require management across Magnox:  Effective use of the Low Level Waste Repository Ltd (LLWR) framework  Prior to the interim state – reactor contract and implementation of the dismantling waste (Harwell and LLW joint waste management plan Winfrith only) and other (JWMP). decommissioning waste will be  Simplifying the management of LLW generated. Nuclear materials and Fuel Element Debris (FED) by other legacy waste will be retrieved establishing a disposal route to LLWR. from existing storage facilities for  Use of cost-effective and fit-for- management. purpose containers for packaging ILW  During C&M / quiescence – small (see Figure 7), LLW and VLLW. volumes of C&M LLW will be  Adopt staged packaging of highly generated from routine monitoring tritiated waste (Chapelcross only) to and inspection activities. improve confidence in disposability.  During reactor dismantling and FSC –  Transfer of nuclear materials off-site large volumes of reactor dismantling for management (see Figure 6). waste will be generated at the Magnox reactor sites. Waste from the  Inter-site transfer of waste for demolition of remaining redundant management (ie pond skips and facilities and contaminated land IONSIVs) to reduce the number of remediation will also require retrieval/processing plant required management across the 12 sites. (see Figure 6).  Maximising the use of existing assets 5.1.1 Strategy by consolidating ILW packages The Magnox radioactive waste strategy is to requiring storage (see Figure 6). retrieve and manage waste, making use  Reduce volumes of LLW/VLLW appropriate routes (see Table 1). In general, generated from contamianted land LLW will be sent off-site and ILW will be by management in-situ where packaged for ILW disposal, interim stored practicable until FSC. and then sent to a disposal facility when it becomes available. Consolidation of ILW The sites will adopt this generic packages for interim storage will be utilised decommissioning strategy as appropriate (see to make efficient use of existing assets. Appendices).

12 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 7: ILW packaging containers.

Type VI Ductile Cast Iron MOSAIK DCIC 6m3 concrete box TRUShield Container (DCIC)

3m3 stainless steel 500L drum 4M box container / drum

Figure 6: inter-site waste transfers.

5.1.2 Routes The implementation of the Magnox strategy disposal facility (GDF) for disposal. This is for the management of radioactive waste is assumed to become available from 2040. through the routes shown in Table 1. All Waste will be sent to GDF in accordance with the GDF Emplacement Schedule. routes are currently available except facilities for ILW disposal. For Scottish sites ILW packages will be stored on-site and above ground for a period of up to For English and Welsh sites it is assumed that 300 years followed by management/disposal. ILW packages will be sent to the geological

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5.1.3 Challenges Key challenges associated with the strategy  Gaining transport approvals for ILW going forward include: packages.  Changing ILW waste packaging to the  Optimisation of management routes use of new containers at some sites. for problematic wastes.  Demonstration of disposability of ILW  Supply chain availability for routes packages through the Radioactive diverting waste away from disposal. Waste Management Limited (RWM)  Availability of routes for radioactive letter of compliance (LoC) process. asbestos.  Gaining permissions for consolidated ILW package storage.

Table 1: Radioactive wastes – planned management routes.

Treatment to enable Interim storage VLLW & LA LLW Disposal to alternative Reuse / Recycle & disposal as disposal2 LLWR management routes ILW Metals (including pond skips and Decontamination     MCI) Oils, solvents & Incineration    solid combustibles Nuclear materials   and sources

Sand and gravel Decontamination   

Decay storage Desiccant    Wash and incinerate Concrete, building structures,    asbestos & soils Liquors, sludges & Incineration   resins Encapsulation

SCRU filters Decontamination  

Segregation FED Compaction   Dissolution

MAC Decay storage  

Graphite 

IONSIV cartridges 

2 Including disposal of VLLW to specified landfill sites or controlled burial of low activity (LA) LLW to permitted landfill facilities.

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5.2 Non-Radioactive Waste NDA Objective:  Applying the proximity principle, ie managing waste as close to the site of  To reduce waste generation and production as practicable. optimise management practices for non-radioactive wastes at NDA sites.  Reducing new build requirements by This includes hazardous and inert consolidating ILW treatment and wastes. storage between sites.  Reusing inert wastes from Non-radioactive waste accounts for the decommissioning for backfilling largest volume of waste arising on each of the voidage and by re-profiling land to

Magnox sites. Examples of this waste include: avoid or reduce importing materials  Prior to the interim state – large on-site for restoration. volumes of waste will be generated In addition, wherever possible, removal of from the demolition of site buildings asbestos will be scheduled to coincide with and facilities. the decommissioning of associated plant  During C&M / quiescence – small items. If, however this is not possible, then

volumes of waste will be generated management of asbestos will be prioritised.

from the demolition of ILW stores and maintenance of any facilities

remaining.

 During reactor dismantling and FSC –

large volumes of reactor dismantling waste will be generated. Waste from

Bradwell turbine hall demolition

the demolition of remaining redundant facilities and contaminated land remediation will also require management.

5.2.1 Strategy The Magnox non-radioactive waste strategy is to retrieve and manage waste, making use appropriate routes (see Table 2). Key aspects to the Magnox non-radioactive waste strategy includes:  Continuing to reduce the amount of non-radioactive waste produced using Hunterston A non-radioactive waste management current good practices.  Pre-treatment involving waste segregation as far as reasonably practicable to enable appropriate management.  Applying the waste hierarchy (ie to reuse and recycle in preference to energy recovery and disposal).

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5.2.2 Routes 5.2.3 Challenges The implementation of the Magnox strategy Key challenges associated with the strategy for the management of non-radioactive waste going forward include: is through the routes shown in Table 2.  Availability of asbestos management All routes are currently available and will be routes during reactor dismantling for required throughout the whole lifecycle of the the Magnox reactor sites. site. Magnox currently diverts a large amount of waste from landfill disposal by applying the waste hierarchy. Table 2: Non-radioactive wastes – planned management routes.

Reuse/ Recycling – Recycling – Reuse recycling – non- Incineration Disposal hazardous inert hazardous Redundant plant    & equipment

Mercury  

Concrete, rubble  and soil

Metals  

Sewage  

Waste oil and   solvents

Zinc bromide  

Hazardous contaminated   soil & concrete Asbestos & fibre  insulation Other hazardous    waste

Other inert waste  

Other non-    hazardous waste

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5.3 Aqueous and Gaseous Discharges Key aspects to the Magnox discharge strategy NDA Objective: include:  To reduce the environmental impact of  Reducing discharges in line with radioactive liquid and gaseous OSPAR and the UK Strategy for discharges in accordance with the UK Radioactive Discharges. Strategy for Radioactive Discharges.  Applying appropriate techniques to Aqueous and gaseous discharges are reduce the impact of the discharges generated at sites during operations and on the environment (see Table 3). decommissioning. Examples of discharges For Magnox, regulatory limits and conditions generated across the lifecycle include: are imposed on the quantity and quality of  Prior to the interim state – liquid and discharges. Prior to the implementation of a gaseous discharges will require project, consideration is given to the impact it management as ponds are drained, will have on existing discharges. reactors / facilities dismantled and Aqueous and gaseous radioactive discharges waste is processed. from the Magnox sites are all compliant with  During C&M / quiescence – there will and generally well below the limits set in the be minimal liquid effluent discharges EPR10 permits / RSA93 authorisations for the during this period. Gaseous sites. discharges from reactor safestore, Non-radioactive discharges are also controlled ILW store or other facilities remaining by limits where applicable under the relevant on the site will continue at very low regulation (eg EPR10, Water Environment levels. (Controlled Activities) (Scotland) Regulations  During reactor dismantling and FSC – 2011 or Pollution Prevention and Control liquid and gaseous discharges will (Scotland) Regulations 2000). require management as remaining In general, the volumes of all types of reactors and facilities are dismantled discharges have decreased significantly as the and waste is processed. sites have transitioned from operational to decommissioning activities. Discharges 5.3.1 Strategy should remain low during decommissioning; The Magnox strategy for the management of however, at times it may be appropriate for radioactive aqueous and gaseous discharges discharges to increase for specific campaigns. is aligned to the requirements of the site Discharges will cease once decommissioning is permit/authorisation to apply Best Available complete and the site end state has been Techniques (BAT) in England and Wales / achieved. Best Practicable Means (BPM) in Scotland to optimise radioactive discharges.

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5.3.2 Routes 5.3.3 Challenges The implementation of the Magnox strategy Key challenges associated with the strategy for the management of liquid and gaseous going forward include: discharges is through the mechanisms shown  Establishing arrangements for in Table 3. managing discharges during periods In general, these management routes exist, of quiescence. however sites may need to replace or modify existing systems prior to the interim state to manage the volumes of effluent generated.

In addition, it is recognised that appropriate changes to the treatment processes and discharge routes will need to be made during the sites lifecycle to reflect the changing needs. Table 3: Aqueous and gaseous discharges – planned management routes.

Active Pond Water Sediment Sewage Effluent Abatement Treatment Oil separator traps/ treatment Treatment (eg filtration) Plant settling tanks plants Plant Radioactive aqueous effluent   (pond water, active drains) Non-radioactive aqueous effluent    (sewage, surface water drains) Radioactive gaseous discharges (reactor  buildings, ILW store, waste processing) Non-radioactive gaseous  discharges

18 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

6 Strategy Implementation The strategy will be implemented through the 6.2.2 Waste Management programmes described below. Waste Management consists

of three sub-programmes: 6.1 Implementation during Defuelling  The defuelling programme is being Waste Strategy and Permissioning – responsible for the coordinated through the Magnox Operating development and integration of the Plan (MOP). decommissioning and waste The MOP is an integrated programme management strategy; preparation of ILW and LLW disposability cases; and covering all NDA business areas associated assurance. with the management of spent Magnox fuel. The MOP helps to ensure the safe and cost  Waste Projects – responsible for the design, procurement, installation and effective delivery of the NDA strategy to commissioning of plant, equipment reprocess all Magnox spent fuel by 2020. and systems required to deliver the waste management strategy. 6.2 Implementation prior to the Interim State  Waste Operations – responsible for the implementation of the waste 6.2.1 Decommissioning management strategy; operation of waste plants, including ILW stores; Decommissioning consists of disposition of all LLW, hazardous and four sub-programmes: conventional waste off the site.  Ponds – responsible for the removal of 6.2.3 Asset Management waste and redundant furniture from Asset Management consists fuel storage ponds, draining pond of two sub-programmes: water and stabilising pond surfaces, decommissioning existing effluent  Asset Management – treatment plants and delivery of new, responsible for managing the physical fit-for-purpose effluent treatment assets across the 12 sites. plants.  Care and Maintenance – responsible  Plant and Structures – responsible for for establishing the arrangements to asbestos removal, deplanting, accept and manage sites as each demolition and preparation of the achieves its defined interim state safestores for C&M. Implementation entry configuration. will be through the use of conventional waste removal and 6.3 Implementation during the Interim demolition techniques. State  Site Restoration – responsible for In general, when a site enters the interim land quality, remediation and state, the responsibility for the management groundwater monitoring. of that site will be transferred to the Care and Maintenance Programme. Management of a  Reactors – responsible for the site during the interim state will include dismantling of Winfrith SGHWR and ensuring the site meets the requirements of Dragon reactors; and Harwell BEPO, the nuclear site license and DIDO and PLUTO reactors. permit/authorisation and management of any facilities and waste on-site.

19 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

7 Assumptions and Risks

7.1 Assumptions The development of the strategies described  Waste consolidation strategies will in this document is based on the following receive necessary permissions assumptions: (including planning permission).  Government policy, standards,  There will be a reasonably practicable legislative and regulatory interpretation of the ‘no danger’ environment remain unchanged, or clause in the Nuclear Installations Act changes pending have no significant 1965 (as amended) so as to facilitate impact. delicensing.  Regulators adopt a consistent and  Site funding plans will allow the proportionate approach. delivery of the lifecycle strategy to the Lifetime Plan schedule.  External licensed conventional, hazardous material and special waste The validity and implications of these disposal facilities will be available to assumptions are kept under review. receive all non-radioactive material requiring removal from the site. 7.2 Risks  The LLWR waste acceptance criteria The strategies in this document have been (WAC) will not change significantly to determined following extensive research, the extent that baseline plans are not design and development programmes carried achievable. out over many years. However, it is  There will be sufficient capacity recognised that not all of the technologies available through the supply chain to required to support the existing strategies are provide alternatives to LLWR disposal fully developed for site implementation. such as treatment of metallic and The Magnox technical baseline underpinning combustible LLW, and VLLW and research and development (TBuRD) document controlled burial of LLW (subject to identifies the technology readiness level (TRL) meeting relevant WAC). of the baseline technologies and the  ILW packages in their passively safe associated underpinning research and condition will be acceptable for development work required to improve the disposal in the GDF. TRL for implementation. Table 4 shows the key generic threats to the  For planning purposes, the GDF for implementation of the strategies set out in ILW will be operational from 2040 for this document. Key opportunities currently packaged wastes in England and being investigated are shown in Table 5. Wales, with a national prioritised programme for waste emplacement. The gaps, threats and opportunities relating Access to the GDF will remain to decommissioning and waste management available for use during FSC. which have been identified throughout this  Near site near surface disposal document have been reviewed and an action facilities for packaged wastes in plan developed. Scotland will be available within 300 years.

20 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Table 4: Key Threats.

Topic Threat Mitigation

Interim state There is a threat that unidentified emergent scope is Frequent engagement with regulators to reach entry required for sites to enter the interim state. agreement on interim entry states for redundant contaminated structures, safestores and land.

There is a threat that knowledge will be lost during Use of appropriate mechanisms to record the interim state which will impact on FSC. information about all plant/facilities to remain during the interim state.

Waste There is a threat that inter-site transfers for waste Continuing engagement with stakeholders consolidation storage consolidation is not approved. (SSGs, Local Authorities, Regulators etc).

Waste storage consolidation strategy cannot be Optimise usage of waste container capacity implemented due to additional waste packages e.g. through segregation, compaction, filling being produced, beyond the estimated base and co-packaging of wastes as appropriate. numbers that results in the store capacities at Monitor container forecast on a regular basis Berkeley, Bradwell and Harwell being exceeded. so that appropriate action can be taken in the event that additional waste containers and/or a new store(s) are required.

Waste There is a threat that disposability cases cannot be Dialogue continues with RWM and additional packaging made for some waste requiring packaging for ILW focus on potential problematic disposal. wastes/packaging.

Plant There is a threat that plants do not achieve their Provide a focussed approach to continual Operations design throughput specification which results in improvements. extended operations.

Waste disposal There is a threat that LLWR will no longer be able to Support LLWR who are investigating the scale accept certain LLW eg asbestos. of the problem and the potential opportunities.

Table 5: Key Opportunities.

Topic Opportunity Potential Benefit Enabling Plans

Site restoration There is an opportunity to optimise Significantly reduce the Strategic options assessment end states through considering in- amount of waste generated and business case to be situ disposal of sub-surface and requiring management. developed for pilot sites contaminated concrete structures (ie (Winfrith and Trawsfynydd). ponds, vaults).

Reactor There is an opportunity to review the Avoid nugatory work (eg Strategic options assessment dismantling optimised timing for carrying out safestore preparation), avoid and business case to be reactor dismantling. loss of workforce/knowledge developed. and enable potential early release of land.

Non-standard There is an opportunity to review the Optimisation of waste Early characterisation of wastes strategy for non-standard wastes. management routes, lifecycle wastes and review strategies cost savings. for all non-standard wastes.

21 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Topic Opportunity Potential Benefit Enabling Plans

Waste There is an opportunity to review and Avoid storage of ILW Strategic options assessment packaging and optimise the Wylfa ILW packaging packages at Wylfa site. and business case to be interim storage and interim storage strategy. developed.

There is an opportunity to review the Use of alternative waste Review of characterisation current strategy for Bradwell FED management routes which information and strategic disposition. may reduce environmental options assessment. impacts and reduce timescales and costs.

Long-term There is an opportunity to optimise Reduce period of long-term Support Scottish Government storage Scottish sites long-term (up to 300 storage and reduce cost. and NDA in development of years) storage strategy. strategy and plans as required.

8 Monitoring and Evaluation Review of this document will be undertaken  Long term plans for national on a cycle of no more than three years, action repositories may change and affect plans will be reviewed annually (see Figure 8). the assumptions in the strategy. It is foreseeable that significant events occur  Changes to a site Licence Condition 35 within the three year review cycle that decommissioning programme. requires the strategy to be updated early.  Lessons learned from site These events (triggers) may include, but not implementation. limited to:  New scientific or technical research or  Changes in policy, legislation, other advances. regulation and/or NDA strategy.  Non-availability of a waste management route or change in WAC.

Figure 8: monitoring and evaluation. 2016 2017 2018 2019 2020 2021 2022 FSC

Strategy period

Strategy Re-issue every 3 review cycle years

Action plan Annual action review plan update

Re-issue brought Trigger forward due to trigger

22 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

9 Communication and Consultation

9.1 Regulatory and Stakeholder Input Recent engagements include: and Consultation  Transfer of nuclear materials from The development of the strategies contained Harwell and Winfrith to other NDA within this document has been undertaken in sites. consultation and with input from the NDA,  Inter-site transfer of ILW for regulators and other stakeholders. Other key management. stakeholders include Government, Local Planning Authorities, Site Stakeholder Groups  Revisions to ILW packaging strategy. (SSGs), Nuclear Legacy Advisory Forum  Optimisation of the number and (NuLeAF) and local interest groups. location of ILW storage facilities. A proportionate approach to the involvement  Proposals for a new Harwell ILW of and engagement with external Store. stakeholders is used in strategic options assessment.  Decommissioning of the Harwell Significant changes to this strategy are taken Liquid Effluent Treatment Plant to the NDA Senior Strategy Committee (SSC) (LETP). for endorsement.  Winfrith site end state optimisation. Regulators are informed of strategic options  Decommissioning strategy and studies being undertaken. In some cases it is interim states. appropriate that regulators are invited to participate in the process, although to 9.3 Accessibility maintain their independence they may choose This document is unrestricted and publicly to do so as observers. accessible via the Magnox website Changes to individual sites decommissioning (www.magnoxsites.com). and radioactive waste management strategy Other company documents are available upon is regulated through Licence Condition 35. application via the Magnox communications

department. 9.2 Communication

Progress against delivery of the decommissioning and waste management strategies are communicated to regulators and other stakeholders on a regular basis as are any potential changes to the strategies and implementation plans.

Whessoe Tanks at the LETP at Harwell

Artists impression of the new Harwell ILW Store

23 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

10 Definitions

As low as reasonably Radiological doses or risks from a source of exposure are as low as reasonably achievable when achievable (ALARA) they are consistent with the relevant dose or target standard and have been reduced to a level that represents a balance between radiological and other factors. The level of protection may then be said to be optimised.

As low as reasonably To satisfy the ALARP principle, measures necessary to reduce risk may be taken until or unless the practicable (ALARP) cost of those measures, whether in money, time or trouble, is disproportionate to the reduction in risk.

Care and maintenance The physical, chemical and radiological conditions at commencement of C&M. This includes any (C&M) entry state passive or active control measures intended to last into and throughout C&M.

Care and maintenance The programme of decommissioning and waste management activities necessary to enable the site preparations (C&MP) to enter C&M. A site enters C&M preparations when they carry out activities to permanently disable the reactors.

Final site clearance The programme of decommissioning and waste management activities necessary to achieve the site end state.

Hazardous waste Controlled waste that contains any substance specified in The Hazardous Waste (England and Wales) Regulations 2005 and the Special Waste (Scotland) Regulations 2004. These include oils, acids and materials such as asbestos

Higher activity waste HAW includes high level waste, intermediate level waste, and some low level waste unsuitable for (HAW) prompt disposal at the LLW Repository.

Interim state A natural milestone or decision point in the site restoration programme that typically represents a significant reduction in risk and hazard and a change in how the Site is managed.

Interim end state A state where no further physical decommissioning and restoration works are carried out and the site end state is reached passively mainly as a consequence of radioactive decay during the period of quiescence.

Intermediate level Wastes exceeding the upper boundaries for LLW, but which do not require heating to be taken into waste (ILW) account in the design of storage or disposal facilities.

Inert waste Waste subject to the Landfill Directive which does not undergo any significant physical, chemical or biological transformations. The total leachability and pollutant content of the waste and the ecotoxicity of the leachate must be insignificant and pose no danger to surface or groundwater quality. These primarily consist of building rubble and glass.

Low level waste (LLW) Wastes having a radioactive content not exceeding 4 GBq (gigabecquerels) per tonne of alpha, or 12 GBq per tonne of beta/gamma activity.

Nuclear Materials Materials containing uranium or plutonium which have been produced from fuel cycle operations such as enrichment, fuel fabrication and reprocessing. Where these materials have no future value they may need to be managed as waste.

Non-hazardous waste Controlled waste which is not covered by the definition of hazardous waste, but which remains biologically, chemically, or physically active if disposed of to landfill. These include metal, timber and other organic wastes. Non-hazardous wastes result both from site occupation, eg office, kitchen, canteen and garden waste and through decommissioning activities, eg metals and treated wood.

Site end state The condition to which designated land and its associated structures and infrastructure need to be restored such that it can be released for its next use.

Very low level waste Wastes with maximum concentrations of 4MBq (megabecquerels) per tonnes of total activity that (VLLW) can be disposed to specified landfill sites. There is an additional limit for tritium in wastes containing this radionuclide.

Waste Any substance or object the holder discards, intends to discard or is required to discard.

24 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Site Specific Appendices The following appendices contain site specific information about the implementation of the integrated decommissioning and waste management strategy:

 Appendix A: Berkeley Site Pages 26 - 27  Appendix B: Bradwell Site Strategy Pages 28 - 29  Appendix C: Chapelcross Site Strategy Pages 30 - 31  Appendix D: Dungeness A Site Strategy Pages 32 - 33  Appendix E: Harwell Site Strategy Pages 34 - 35  Appendix F: Hinkley Point A Site Strategy Pages 36 - 37  Appendix G: Hunterston A Site Strategy Pages 38 - 39  Appendix H: Oldbury Site Strategy Pages 40 - 41  Appendix I: Sizewell A Site Strategy Pages 42 - 43  Appendix J: Trawsfynydd Site Strategy Pages 44 - 45  Appendix K: Winfrith Site Strategy Pages 46 - 47  Appendix L: Wylfa Site Strategy Pages 48 - 49

The following key is used for the decommissioning strategy tables:  GL – ground level

The following key is used for the radioactive waste strategy wiring diagrams:  Grey boxes – work completed  Black text – waste currently in stock and how it is currently managed  Blue text – waste that is yet to arise  Red text – work to be undertaken prior to entering the interim state  Green text – work to be undertaken after entering the interim state

25 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix A: Berkeley Site Table 6: Berkeley Decommissioning Strategy Overview.

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers taken down and sent off-site (C&M) for management  Back to bare room deplanting  Reactor height reduced  Cladding maintain & repair  Reactor void MAC to remain in-situ Redundant contaminated structures  Ponds demolished and void infilled  Vaults above ground structure to be GL GL demolished, below ground structure (void) to remain in-situ

Pond Active Waste Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void already infilled

Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 1,800 m3 raw waste (ILW)  See Figure 9 for waste management

Type strategy MOSAIK VI DCIC  DCIC Interim storage of Berkeley and GL Oldbury ILW packages (including 3 6m IONSIVs from Dungeness A and concrete TRUShield box Sizewell A) in site ILW store Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

26 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 9: Berkeley Radioactive Waste Strategy Overview.

ILW Chute silo MAC

Package and dry (if ILW CRP resin and sludge required) in DCICs

ILW Vault 2 waste (mainly Interim storage in Transport to GDF FED) Berkeley ILW Store

ILW Vaults 1 and 3 waste (mainly FED) Receive Oldbury DCICs Package and grout ILW gravel into 6m3 concrete boxes and TRUShields

ILW shielded area waste

Off-site treatment ILW desiccant and disposal as VLLW

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

Note: modifications will be required to the existing Berkeley ILW Store to accommodate the storage of 6m3 concrete boxes.

27 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix B: Bradwell Site Strategy Table 7: Bradwell Decommissioning Strategy.

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Back to bare room deplanting  Full recladding  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Vaults to remain in-situ GL GL

Pond Active Waste Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void infilled as suitable material becomes available, void managed until infilled Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ and backfilled with

Non-active drains Active drains Pipelines & grout & tunnels outfalls  Remove above ground pipeline structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land GL remediated to levels agreed with the Areas of Potential regulator Concern (APCs)  Non-radioactive contaminated land Borehole monitoring to be remediated as required to meet

contaminated land & groundwater regulations ILW storage ~ 700 m3 raw waste (ILW)  See Figure 10 for waste management

Type strategy MOSAIK VI DCIC  DCIC Interim storage of Bradwell, GL Dungeness A and Sizewell A ILW packages in site ILW store

Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

28 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 10: Bradwell Radioactive Waste Strategy.

Receive Dungeness A ILW resin and sludge DCICs

ILW sand and gravel

Package and dry (if Interim storage in Transport to GDF required) in DCICs Bradwell ILW Store

ILW MCI

ILW nimonic springs and FED Receive Sizewell A secondary wastes DCICs

Treatment by dissolution ILW FED magnox LLW Package for LLW Transport to LLWR disposal

Package for decay Decay storage in ILW ILW desiccant Transport to LLWR storage Store

Use of available routes (i.e metal Other LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

Note: Bradwell ILW Store will require re-configuration to accommodate the storage of Dungeness A and Sizewell A ILW packages.

29 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix C: Chapelcross Site Strategy Table 8: Chapelcross Decommissioning Strategy.

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M RD & SR LTS FSC phases Interim state Reactor safestore preparations  Boilers taken down and stored on site (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to be demolished  Chapelcross Processing Plant (CXPP) to remain in-situ

GL GL

Ponds CXPP Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void to be infilled

Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains to remain in-situ  Remove above ground pipeline

Non-active drains Active drains Pipelines & structure, below-ground pipeline & tunnels outfalls structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 200 m3 raw waste (ILW)  See Figure 11 for waste management

6m3 strategy MOSAIK concrete DCIC box  Long-term storage (up to 300 years) GL of Chapelcross ILW packages TSVs 500L drum (including staged packaging of

tritiated waste) in site ILW store Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

30 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 11: Chapelcross Radioactive Waste Strategy.

ILW CXPP stainless steel and Transport to Sellafield reactor defuelling waste for management

ILW zeolite skips and fuel skips Package and grout into 6m3 concrete boxes ILW sludge Long-term storage in Transport to future Chapelcross ILW Store ILW disposal facility

ILW pond MAC and cobalt Package and dry (if cartridges required) in DCICs

IL W ceramic pellet waste Overpack in Transport to future 4M boxes ILW disposal facility

ILW CXPP cave line waste Package and weld in stainless steel Long-term storage in containers (staged Chapelcross ILW Store packaging) ILW CXPP process line waste

Overpack Transport to future in HHISOs LLW disposal facility ILW CXPP dismantling waste

Package for decay ILW desiccant storage Decay storage in Transport to LLWR Chapelcross ILW Store ILW mercury and rotary Package for decay pump oil storage

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M Transport to future ILW & Reactor void MAC boxes ILW disposal facility

31 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix D: Dungeness A Site Strategy Table 9: Dungeness A Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Vaults to remain in-situ

GL GL

Ponds Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void partially infilled, remaining void to be managed Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 200 m3 raw waste (ILW)  See Figure 12 for waste management

Type strategy No ILW store MOSAIK VI DCIC  Transport ILW packages to Bradwell DCIC for interim storage Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

32 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 12: Dungeness A Radioactive Strategy

Treatment by FED magnox dissolution

Segregation

ILW nimonic springs

ILW MCI Transport for interim Package and dry (if storage in Bradwell required) in DCICs ILW Store ILW resin and sludge

ILW IONSIV filters

ILW IONSIV cartridges (and Transport to Oldbury high dose rate filters) for management

Off-site treatment ILW desiccant and disposal as VLLW

Transport to Hinkley ILW fuel skips Point A for management

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

33 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix E: Harwell Site Strategy Table 10: Harwell Decommissioning Strategy

Overarching Early reactor dismantling and early achievement of site end state for parts of the site. strategy Strategy RD & PD C&M FSC phases Interim state Reactors  Reactors deplanted and dismantled (C&M)

GL GL GL

DIDO PLUTO BEPO Redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL

Foundations / slabs Voids Drains, tunnels & pipelines  Drains and tunnels removed as required for next planned use GL GL GL  Remove pipeline where practicable

Non-active drains Active drains Pipelines & & tunnels outfalls Land quality  Remove contaminated land as required for next planned use  Delicence areas to be released for next planned use ILW storage ~ 2,800 m3 raw waste (ILW)  See Figure 13 for waste management

6m3 strategy concrete box  Interim storage of Harwell and GL Winfrith ILW packages in site ILW 3m3 box / 500L drum stores drum

GL

Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

34 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 13: Harwell Radioactive Waste Strategy

Encapsulated LETP Liquors & 500 litre drums Sludges

Polymer encapsulation HLA ILW heels in 200l drums

Historic ILW in tube stores

Overpack Stored Nuclear Material Package in to 500L Interim storage in ILW packages into (GLEEP/Zenith) drums in HEC Vault Store SWTCs

Standard RHILW non-gaseous NDS sources Grout in WEP Receive Winfrith Active Handling Faciltiy Thorium & other ILW Decommissioning ILW for packaging Transport to GDF

Package and grout Large RHILW into 3m3 stainless 3 non-gaseous NDS sources Receive Winfrith 6m steel containers concrete boxes g n

i Radiochemical Facility l c

y Decommissioning ILW c

e Package & grout into Interim storage in r

r 3

o 6m concrete boxes Harwell ILW Store f Reactor Decommissioning e l

b ILW a t i u s

3

t Receive Culham 6m o n

concrete boxes e t s a

W Transfer to Low enriched Uranium (LEU) Novapack Capenhurst for management

Transfer to Depleted and Natural ISOs Springfields for reuse/ Uranium recycle

Drummed Contact Handled FHISO/Novapak ILW (CHILW)

Transport to Sellafield Concrete Lined Drums FHISO/TN-Gemini for processing and disposal

DRAGON Waste Modular Flask

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal)

35 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix F: Hinkley Point A Site Strategy Table 11: Hinkley Point A Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Dry vaults to remain in-situ  Wet vaults and other contaminated

GL GL structures to be demolished

Pond Dry vaults Wet vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void already mostly infilled, opportunity to use material from Hinkley Point C site construction Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ Non-active drains Active drains Pipelines &  Remove primary and secondary & tunnels outfalls pipeline structure, tertiary pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 1,200 m3 raw waste (ILW)  See Figure 14 for waste management

6m3 strategy concrete TRUShield box  Interim storage of Hinkley Point A GL ILW packages (including pond skips MOSAIK from Dungeness A, Oldbury and DCIC Sizewell A)in site ILW store Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

36 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 14: Hinkley Point A Radioactive Waste Strategy

ILW resin and sludge

ILW MCI

Package and grout Interim storage in ILW sand and gravel into 6m3 concrete Hinkley Point A ILW Transport to GDF boxes and TRUShields Store

ILW IONSIV cartridges and filters Receive Dungeness A, Oldbury and Sizewell A ILW fuel skips

FED magnox

Segregation

Package and dry (if ILW Nimonic springs required) in DCICs

Off-site treatment ILW desiccant and disposal as VLLW

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

37 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix G: Hunterston A Site Strategy Table 12: Hunterston A Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M RD & SR LTS FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Full recladding  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ (overbuilding replaced at a lower height)  Solid Active Waste Building (SAWB)

GL GL bunkers to remain in-situ

Ponds SAWB bunkers Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void already infilled

Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ

Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 2,700 m3 raw waste (ILW)  See Figure 15 for waste management

3m3 strategy box / drum  Long-term storage (up to 300 years) GL of Hunterston A ILW packages in site ILW store

Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

38 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 15: Hunterston A Radioactive Waste Strategy

ILW sand

ILW acids

Encapsulation in Long-term storage in Transport to future ILW resin and sludge stainless steel Hunterston A ILW ILW disposal facility containers Store

ILW SAWB bunkers waste

ILW IONSIV cartridges and filters

Decay storage in Package for decay ILW desiccant Hunterston A ILW Transport to LLWR storage Store

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M Transport to future ILW & Reactor void MAC boxes ILW disposal facility

39 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix H: Oldbury Site Strategy Table 13: Oldbury Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Vaults to be demolished

GL GL

Ponds Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void to be managed, opportunity to use material from Oldbury B site construction Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 800 m3 raw waste (ILW)  See Figure 16 for waste management

Type strategy No ILW store MOSAIK VI DCIC  Transport of ILW packages to DCIC Berkeley for interim storage Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

40 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 16: Oldbury Radioactive Waste Strategy

ILW IONSIV cartridges & filters

ILW MCI Transport for interim Package and dry (if storage in Berkeley required) in DCICs ILW Store ILW resin and sludge

Receive Dungeness A and Sizewell A ILW gravel IONSIVs

ILW nimonic springs & FED magnox

Segregation

Package for LLW LLW FED magnox Transport to LLWR disposal

Transport to Hinkley ILW Fuel skips Point A for management

Off-site treatment ILW desiccant and disposal as VLLW

Use of available routes (i.e metal Other LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

41 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix I: Sizewell A Site Strategy Table 14: Sizewell A Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Vaults to remain in-situ

GL GL

Ponds Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void to be managed

Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ

Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 100 m3 raw waste (ILW)  See Figure 17 for waste management

Type strategy No ILW store MOSAIK VI DCIC  Transport of ILW packages to DCIC Bradwell for interim storage Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

42 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 17: Sizewell A Radioactive Waste Strategy

ILW IONSIV filters

ILW MCI

Transport for interim Package and dry (if ILW resin and sludge storage in Bradwell required) in DCICs ILW Store

ILW sand and gravel

ILW nimonic springs

Segregation

Package for LLW FED magnox Transport to LLWR disposal

Transport to Hinkley ILW fuel skips Point A for management

ILW IONSIV cartridges (and Transport to Oldbury high dose rate filters) for management

Off-site treatment ILW desiccant and disposal as VLLW

Use of available routes (i.e metal Other LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

43 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix J: Trawsfynydd Site Strategy Table 15: Trawsfynydd Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP C&M FSC phases Interim state Reactor safestore preparations  Reactors height reduced (C&M)  Boilers height reduced  Back to bare room deplanting  Full recladding  Reactor void MAC to remain in-situ

Redundant contaminated structures  Ponds to remain in-situ  Vaults to remain in-situ GL GL  Opportunity for in-situ disposal of contaminated structures

Pond Vaults Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void already infilled

Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 2,000 m3 raw waste (ILW)  See Figure 18 for waste management

3m3 strategy box / 1803 drum drum  Interim storage of Trawsfynydd ILW GL packages in site ILW store

Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site. Opportunity for in-situ disposal of active waste vaults below-ground concrete structures.

44 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 18: Trawsfynydd Radioactive Waste Strategy

ILW FED

ILW MAC

Encapsulation in Interim storage in ILW MCI stainless steel Trawsfyndyy ILW Transport to GDF containers Store

ILW sand and gravel

ILW sludge and oil

Repackage prior to disposal Interim storage in Package in 1803 mild ILW resins Trawsfyndyy ILW steel drums Store

Off-site treatment ILW desiccant and disposal as VLLW

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

45 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix K: Winfrith Site Strategy Table 16: Winfrith Decommissioning Strategy

Overarching Early reactor dismantling and achievement of site end state. strategy Strategy RD & SR Quiescence Site end state phases Interim end Reactors  Reactors deplanted and dismantled state  Opportunity for in-situ disposal of (quiescence) below-ground contaminated structures (including SGHWR basement)

GL GL

SGHWR Dragon Redundant structures  Demolition to below ground level and landscaped

GL

Buildings Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ

Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land GL surface contamination to be removed and in-situ contamination with institutional controls for deeper contamination Borehole monitoring  Non-radioactive contaminated land to be remediated as required to meet contaminated land & groundwater regulations ILW storage ~ 70 m3 raw waste (ILW)  See Figure 19 for waste management No ILW store 6m3 strategy concrete  Transport of ILW packages to Harwell box for interim storage Site end state Site released for next planned use.

46 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 19: Winfrith Radioactive Waste Strategy

Dragon Decommissioning ILW

SGHWR Decommissioning ILW

Transport to Harwell Package & grout into for interim storage in Miscellaneous ILW stored in 6m3 concrete boxes SGHWR Harwell ILW Store

ILW Concrete Lined Drums

ILW not suitable for packaging in 6m3 concrete boxes Transfer to Harwell for processing & packaging Thorium

Recovery at Natural and Depleted Springfields for Uranium re-use/recycle

Package in 500L Short-term storage at Transport to LLWR for SGHWR sludge drums Winfrith disposal

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal)

47 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Appendix L: Wylfa Site Strategy Table 17: Wylfa Decommissioning Strategy

Overarching Deferred reactor dismantling (85 years from reactor shutdown). strategy Strategy C&MP (& defuelling) C&M FSC phases Interim state Reactor safestore preparations  Boilers to remain in-situ (C&M)  Risk based deplanting  Cladding maintain & repair  Reactor void MAC to remain in-situ

Redundant contaminated structures  Dry store cells (DSC) 1-5 to remain in- situ

GL

DSCs Other redundant structures  Demolition to slab level  Voids to be infilled as suitable material becomes available GL GL  Turbine Hall void to be managed, opportunity to use material from Wylfa Newydd site construction Foundations / slabs Turbine Hall Drains, tunnels & pipelines  Non-active drains and tunnels to remain in-situ GL GL GL  Active drains remove inner, outer to remain in-situ

Non-active drains Active drains Pipelines &  Remove above ground pipeline & tunnels outfalls structure, below-ground pipeline structure to remain Land quality  Radioactive contaminated land to be GL contained in-situ Areas of Potential  Non-radioactive contaminated land Concern (APCs) to be remediated as required to meet Borehole monitoring contaminated land & groundwater

regulations ILW storage ~ 20 m3 raw waste (ILW)  See Figure 20 for waste management

Type strategy No ILW store MOSAIK VI DCIC  DCIC Interim storage of Wylfa ILW packages in converted existing facility (such as reactor safestore) Site end state Reactors dismantled. All facilities removed and below-ground structures made safe. Contamianted land remediated as required. All waste removed from site.

48 Magnox Ltd – Integrated Decommissioning and Waste Management Strategy – May 2016

Figure 20: Wylfa Radioactive Waste Strategy

ILW MCI

Interim storage in Package and dry (if converted existing ILW DSC4 corrosion debris Transport to GDF required) in DCICs facility (reactor safestore)

ILW DSC4 skip debris

Off-site treatment ILW Desiccant and disposal as VLLW

Use of available routes (i.e metal LLW Segregation recycling, incineration, VLLW, LLW disposal) LLW

Reactor dismantling waste Encapsualtion in 4M ILW Transport to GDF & Reactor void MAC boxes

49