Higher-activity radioactive waste: implementation strategy

2 The Implementation Strategy

2.1.1The 2011 Policy proposed that a Strategy be developed to help implement the Policy. As a result, the Scottish Government developed this Strategy, with guidance from a Project Board comprising the NDA, waste producers and owners, local government, SEPA and ONR. CoRWM, representatives of the local Site Stakeholder Groups, and the Nuclear Free Local Authorities ( NFLA) were observers on the Board and actively participated in discussions.

2.2 Aim/Scope

2.2.1 The overarching aim of this Strategy is to expand on the framework provided by the 2011 Policy, to allow waste management decisions to be taken to ensure that the Policy is implemented in a safe, environmentally acceptable and cost-effective manner. The Strategy sets out key future milestones for the implementation of the Policy.

2.2.2 The Strategy does not address site-specific issues. It is recognised that appropriate waste management solutions at one site may be different from those at another site. The Strategy is not prescriptive about which management solutions should be used in specific circumstances.

2.2.3 The Strategy addresses all the issues that are considered to be necessary at this time to provide clarity for the implementation of the Policy. During the formation of the Strategy, some of the issues which the 2011 Policy considered as relevant for inclusion in the Strategy were reviewed. It was decided that some issues were no longer relevant and others will be addressed in the future.

2.2.4 The Strategy recognises that there are a number of additional considerations that could impact on how management options are taken forward in the future, in particular:

• The emergence of new technologies that might allow for more rapid and effective long-term management of waste;
• The demonstration of the safety and effectiveness of management options currently being explored; and
• Evaluation of ethical and societal attitudes to waste management options, especially with respect to the issue of intergenerational equity.

2.2.5 The Strategy describes the three phases of work and key higher activity waste milestones from 2016 to post 2070. Setting out clear timescales towards disposal solutions is important to develop suitable waste management options to minimise the burden for future generations.

2.2.6 The Strategy recognises that a significant proportion of HAW in Scotland will not arise for many years under current planning assumptions. This is mainly due to current site plans for Magnox reactors and AGRs (Advanced Gas-Cooled Reactors) to be left in safe and quiescent state for several decades until reactor dismantling commences. It also recognises that some HAW in Scotland will require the development of new long-term waste management options.

2.3 Assumptions

2.3.1 The Strategy sets out the key stages for the effective implementation of the 2011 Policy. It is important to note, however, that given the very long timescales involved over which this Strategy is likely to cover, there is a degree of uncertainty about the exact timing of future events and decisions. It is important that decisions are taken in the light of the best information available at the time they need to be made. Making decisions ahead of time misses the opportunity to take account of new information, and risks the decision being reopened before it takes effect.

2.3.2 Annex B sets out an overview of the HAW that has arisen or is expected to arise in Scotland and the current management arrangements for the waste.

2.3.3 The assumptions made when considering waste management options allowed by the 2011 Policy include, but are not limited to, the following;

• Radioactive waste management cases are required to support waste management plans and particularly packaging proposals. An important input to this document is the Letter of Compliance process. The Scottish Government recognises the important role of the Letter of Compliance (LoC) process in assuring the quality and safety of packaged HAW (see Paras 2.6.24-2.6.26 for further details). The LoC process is scrutinised by ONR and SEPA to ensure that it is fit for purpose with respect to the potential for long-term storage of waste packages in Scotland.
• In the event of a continuing need for storage of waste beyond the lifetime of the current storage plans, stores could be replaced periodically as required. Packages will be monitored and inspected periodically during storage, in line with regulatory requirements and guidance.
• The current regulatory arrangements to ensure that packaged waste is adequately monitored and inspected during any periods of storage are fit for purpose.
• Developers will need to demonstrate how disposal facilities will be monitored and how waste packages, or waste could be retrieved if necessary.

2.4 Key Principles

2.4.1The Strategy is based around the overarching principles set out in the 2011 Policy (Section 2.01):

• The level of protection provided to people and the environment against radiological and any other hazards of the treatment or storage or disposal of the waste at the time decisions are taken, now and in the future will be consistent with the standards in place at the time;
• Developers and operators of facilities will engage with stakeholders, including local communities where any facility may be located, throughout the process of managing the waste;
• The waste hierarchy should always be considered in managing wastes to ensure that wastes are not unnecessarily created and that all other options are adequately considered before a decision to dispose is taken;
• The proximity principle should be taken into account for all long-term management options; and
• Management of HAW must be undertaken in compliance with all legal and regulatory requirements;

2.4.2 This Strategy also recognises that:

• planning for HAW management throughout its lifecycle, including appropriate characterisation and segregation of wastes is critical to flexible management of HAW;
• integration of strategies for all wastes ( HAW, low level radioactive waste and non-radioactive waste) is important nationally and for individual waste producers;
• the development of adequate skills and knowledge resources is important for the effective management of HAW; and
• there is a need to respond and adapt to future technologies by not foreclosing long-term management options.

2.5 Key Phases and Actions

2.5.1 Three phases of work have been developed, each with specific milestones to direct implementation of the Policy. Timescales have been chosen to reflect current plans for the decommissioning of the nuclear licensed sites in Scotland. Figure 3 illustrates the current nuclear sites decommissioning targets against the milestones for each phase of work. Dates are accurate at the publication date of this document.

2.5.2 The dates for each activity are approximate and may be subject to change to reflect new developments and Policy reviews. There may be opportunities to reduce storage periods by establishing management routes earlier which could allow decommissioning timescales to be shortened saving time and costs. Early opportunities to develop near surface disposal technologies will be pursued if possible.

2.5.3 Due consideration must be given to the timescales involved in implementing a final disposal route for wastes. The milestones in each phase have been chosen to prioritise decision making for siting and planning of facilities in Phase 2 to enable construction of facilities at the latest in Phase 3. It is important that the waste burden should not be passed unnecessarily to future generations and that we deal safely and responsibly with our nuclear waste legacy.

2.5.4 In Figure 3 the shorthand term 'challenging waste' refers to HAW which is currently understood, under current technologies, to be unsuitable for near-surface disposal, for instance due to the presence of long lived alpha-emitting radionuclides.

Figure 3: Implementation Strategy Timeline

2.6 Phase 1: 2016-2030

Site status

Under current plans:

• Hunterson A/Chapelcross : Will continue with preparations for entering the Care and Maintenance phase of decommissioning in 2022 and 2028 respectively. Some HAW will be placed in storage facilities during this phase.
• Dounreay : Subject to funding, Dounreay is expected to reach its proposed Interim End State by 2030-2033, by which point all the HAW is expected to be packaged into two storage facilities on the site.
• Hunterston B : Will continue operating until 2023 and will subsequently begin work to prepare for the Care and Maintenance phase. Torness will continue operating until 2030 and will subsequently begin work to prepare for the Care and Maintenance phase

2.6.1 The development of storage methodologies and facilities across Scottish sites for waste arising in the period up until 2030 is currently at an advanced stage. In addition, all sites have worked effectively to develop good relationships with their stakeholders, represented by the respective Site Stakeholder Groups. These groups have developed a good level of understanding of the process of decommissioning on their site, and a mature appreciation of the risks and safety procedures involved in handling and storing nuclear wastes.

2.6.2 During Phase 1, current plans for the construction of first generation interim storage facilities will progress. Storage facilities will be constructed at Dounreay, and at each of the Magnox decommissioning sites, to provide storage capabilities for HAW arising during preparation for Care and Maintenance. At the date of publication, the first of this suite of storage facilities was already operating at Hunterston A, accepting Intermediate Level Waste ( ILW). An ILW store is also operating at Dounreay.

Establishing a new baseline in Phase 1

2.6.3 A baseline provides a basis for the assessment of future innovative proposals for waste management and can be used to monitor progress.

2.6.4 Prior to the publication of the 2011 Policy, the baseline for Higher Activity Waste management in the UK was founded on site specific retrieval, treatment, conditioning and packaging, almost exclusively through grouting. The assumption was that this would be followed by a period of interim storage until a geological disposal facility became available for final disposal of the waste. The existing baseline is therefore incompatible with the 2011 Policy.

2.6.5 A baseline which is compatible with the 2011 Policy will be established in Phase 1.

2.6.6 For the Magnox and EDF Energy sites, the current plans are that there will be deferred reactor dismantling. During Phase 1, the Scottish Government expects all waste owners to review these current baseline assumptions, taking account of all relevant factors including the availability of suitable disposal routes and maintenance of skills and expertise.

2.6.7 The NDA is establishing a new baseline for HAW for its sites in Scotland, which assumes that it will be stored on the site at which it arises for a period of up to 300 years, with stores being maintained, refurbished or replaced as appropriate throughout the storage period. This new baseline will use an initial set of assumptions for the way in which waste covered by the 2011 Policy will be managed in the future and provide a comparison for alternative management options as they develop.

Understanding the inventory

2.6.8 The 2011 Policy recognised that further work was needed to define the waste to be managed in the long-term, both in terms of radionuclides, material type (for example, graphite metal etc.) and volume. This is important data to allow exploration of alternative treatment methods to reduce the volumes of the waste.

2.6.9 NDA prepares the UK Inventory of Radioactive Waste and Materials ^[6] on behalf of the UK Government. This is reviewed periodically with data being supplied by the individual waste producers. The continued development and improvement of the inventory will need to take into account the impact of a different Policy position in Scotland to ensure that data are provided to aid decision making across the whole of the UK.

2.6.10 As part of the work to develop the Strategy, the Scottish Government asked the NDA and the Scottish sites to consider the waste that will arise at their sites and begin to identify which wastes may or may not be suitable for final disposition in near-surface disposal facilities. This programme of work will continue during Phase 1.

2.6.11 Initial results from Magnox and EDF Energy indicate that there may be a range of waste management and near-surface disposal opportunities that could be technically suitable for a good proportion of the HAW streams arising at the Chapelcross, Hunterston A, Hunterston B and Torness sites. A significant future work programme will be required before a fully underpinned near-surface disposal solution is deemed viable.

2.6.12Given the different type of reactors that existed at Dounreay initial studies suggest that 60% of the higher activity waste arising at the site would not be suitable for near-surface disposal due to relatively high concentrations of long lived alpha-emitting radionuclides. This type of ILW waste will need to be stored until alternative waste management solutions are developed. A research programme to investigate alternative management options for these types of wastes will begin by Phase 2.

2.6.13 During this phase, an important aspect of the work will be to provide information to support decision making regarding the need for near-surface disposal facilities suitable for the proportion of the HAW that can be managed via this route.

Research and development

2.6.14 Research and development (R&D) will be required to help develop solutions for the radioactive waste management challenges in Scotland. It is anticipated that, through R&D over the coming phases, further technical solutions will be discovered which could lead to significant opportunities for cost reduction and schedule acceleration. This will enable an informed decision to be made on how to best manage the HAW in Scotland.

2.6.15 R&D is primarily undertaken by the Site Licence Companies and their supply chain partners in line with what is required to deliver their decommissioning plans and management of HAW in line with the 2011 Policy. In addition, the NDA directly maintains a strategic UK wide R&D programme which includes a Direct Research Portfolio that supports strategy development, maintenance of skills and innovation.

2.6.16 Many of Scotland's key R&D topics will support the 2011 Policy and Strategy will match those set out in the NDA's 5 year R&D Plan ^[7] . Topics which align with Scotland's Policy include:

• Application of the Waste Hierarchy
• Alternative waste treatment, with a particular focus on volume reduction
• Underpinning of interim storage
• Alternative disposal approaches (e.g. decay storage, near-surface)
• Improved decommissioning
• Improved characterisation of the waste
• In situ disposal of structures and waste

2.6.17 The Scottish Government will work with the NDA to develop R&D aims for Scotland's Higher Activity Waste Policy and Strategy and ensure no duplication of work. This will include reviewing research under development, prioritising research areas and proposing new projects for areas which are not yet covered by Site Licence Companies, their supply chain or NDA R&D programmes. The Chief Scientific Adviser for Scotland will help the Scottish Government and support NDA R&D projects that address the needs of Scotland's HAW Policy and explore opportunities for collaboration and consolidated learning.

2.6.18 The Scottish Government expects waste owners and producers, as appropriate, to carry out cost analysis for a variety of potential strategic and technical options in order to better inform their decisions and ensure cost effective R&D.

2.6.19 The Scottish Government and the NDA will monitor emerging technologies and communication methodologies from waste management programmes around the world throughout Phases 1, 2 and 3.

2.6.20 The Scottish Government will consider funding and supporting research proposals which support Scottish Government objectives and compliments (and not duplicate) NDA led research on radioactive waste management and environmental remediation via the Contract Research Fund. The Scottish Government will focus this research on environmental remediation, building stakeholder and public confidence, enhancing Scotland's civil nuclear decommissioning capabilities, radioactive waste management options and societal concerns on radioactive waste management.

2.6.21 The Scottish Government, with advice from the Chief Scientific Adviser for Scotland and CoRWM, will work to develop a long-term plan to:

• raise awareness of the radioactive waste challenge in Scotland;
• support opportunities to enhance and promote Scotland's radioactive waste management capabilities internationally; and
• ensure that Scotland is effectively represented within the nuclear decommissioning and radioactive waste management R&D landscape

2.6.22 A list of potential research projects to support this Strategy can be found in Annex C . This list will be reviewed and updated periodically as events develop and the Strategy matures.

2.6.23 In Phase 1 R&D will focus on helping to underpin suitable options for the waste management of HAW for which, under current understanding of technologies and regulation, the prospect of near-surface disposal solutions is closest. The Scottish Government will work with the NDA to establish a timeline for bringing forward credible strategic options for the management of the waste beyond Phase 1.

Letter of Compliance (LoC) process

2.6.24 Before site operators commit to retrieval and packaging of waste, regulators require them to produce a Radioactive Waste Management Case ( RWMC). This is a summary document which provides a transparent demonstration of how the waste will be managed throughout its lifecycle, its compatibility with existing and future planned management and disposal options and how the key elements of long-term safety and environmental performance will be delivered.

2.6.25 An important input into the RWMC is the Letter of Compliance (LoC). LoC's are obtained through applying the Disposability Assessment Process in which the waste packaging plans are assessed against the RWM generic waste packaging specifications, the safety case and compatibility with disposing in a deep geological disposal facility. Although this disposal route will not be used for Scotland's waste this process has remained the basis for assessments in Scotland, as there is a consensus in the industry and from regulators that this will also measure the suitability of waste packages for extended periods of storage ^[8] .

2.6.26 The overall objective of the LoC assessment process is to give confidence to all stakeholders that the future management of waste packages has been taken into account as an integral part of their development and manufacture. The LoC process is kept under review which will allow consideration of whether there needs to be further changes to the process to recognise that some wastes are destined for near-surface disposal.

Intermediate Level Waste Storage Facility at Hunterston A

Summary of Phase 1

During Phase 1:

• First generation storage facilities will be built and operated, to store waste at Dounreay and at each of the Magnox sites.
• The Scottish Government will continue to support the on-going NDA initiatives to reduce HAW volumes from decommissioning sites.
• R&D will be undertaken by SLCs/Supply Chain/ NDA to help the further development of credible options for the management of radioactive waste.
• The NDA and the Scottish sites will continue to evaluate the waste that will arise at their sites and identify which wastes may or may not be suitable for disposal using emerging near-surface disposal technologies.
• RWM will review its current LoC process in support of the development of near surface disposal concepts for wastes arising in Scotland.
• A new baseline will be implemented.

Intermediate Level Waste Storage Facility at Hunterston A

2.7 Phase 2: 2030-2070

Site status

Under current plans:

• Chapelcross/Hunterson A : Will be in Care and Maintenance with some HAW in storage. Only HAW associated with the dismantling of the reactors yet to be retrieved.
• Dounreay : All HAW will be in storage.
• Torness/Hunterston B : Will enter Care and Maintenance early in phase 2.

During this phase little HAW is expected to arise from the sites. The ILW stores built in Phase 1 will be under management by the responsible site mangers.

2.7.1 During Phase 2, all HAW will either be in safe and secure storage in the first generation of storage facilities or still within the reactors. This arrangement will provide a suitable amount of time for the implementation of plans from Phase 1.

2.7.2 In Phase 2 there will be a requirement to plan for the construction of second generation storage facilities to replace stores built prior to or during Phase 1. This will ensure continued safe management of waste generated during site Care and Maintenance phases in the period before a final disposal route is selected and implemented. The 2011 Policy requires that decisions to construct new storage facilities should be based on compliance with a period of stability and capability of at least 100 years.

2.7.3The Scottish Government anticipate that towards the end of Phase 1, there will be sufficient information to inform decision making regarding the need for one or more near-surface disposal facilities.

2.7.4 In Phase 2 the design of a disposal facility will be developed and a detailed programme to select a site or sites, including comprehensive stakeholder engagement, will be carried out. This will enable completion of the planning process and construction of a disposal facility early in Phase 3. There are significant operational and financial benefits in having a disposal facility available to accept waste from reactor dismantlement at the two Magnox sites (and ultimately, the two EDF Energy sites), without the need for a storage phase. This would remove the requirement to build storage facilities for this major element of the waste inventory. A major consideration in the planning of disposal facilities will be to coordinate with developing plans for the Care and Maintenance phases in order to allow for direct disposal of these wastes, and the timing of the construction of the disposal facility will be kept under review.

Research and development in Phase 2

2.7.5 There are two R&D work streams to be undertaken in Phase 2:

i. Where appropriate, R&D to support the long-term management of HAW, for which under current technology and regulation the prospect of near-surface disposal is closest. This research will continue from Phase 1.

ii. R&D into credible options for waste management of HAW currently understood to be unsuitable for near-surface disposal. An example of these types of wastes is raffinate waste at Dounreay.

2.7.6 The second work stream (ii) will involve the Scottish Government working with the NDA to develop a R&D programme to look into credible options for the management of these wastes currently understood as unsuitable for near-surface disposal.

Siting of facilities

2.7.7 Under current plans the first generation of stores built for storing HAW at Dounreay and Magnox sites during their Care and Maintenance phase will be on the site where the waste arises.

2.7.8 The 2011 Policy states that there will not be a prescriptive definition of 'near to the site' for disposal or storage facilities but it does presume that waste will be dealt with as close as is possible to the site where it was produced, thus minimising the need to transport the waste over long distances. The 2011 Policy recognises that where the waste is produced and where it can be stored or disposed of may be in different locations, particularly for non-nuclear industry waste producers. Decisions will be taken on a case by case basis and will be subject to robust regulatory requirements and the principles underlying the Policy.

2.7.9 The Scottish Government and the NDA agree that waste consolidation as a radioactive waste management option has the potential to deliver business benefits. Any decision to consolidate waste will have to be consistent with the national policy and the proximity principles.

2.7.10 Waste producers and owners will need to take account of the Policy aims and principles in making their future planning assumptions. The Scottish Government expects these groups to work closely with planning authorities and regulators in the design and siting of storage and disposal facilities for radioactive waste.

2.7.11 Engagement with local communities and stakeholders throughout the process of developing a near-surface disposal facility will be a critical part of this process. The Scottish Government will work with COSLA, the Forum on Stakeholder Confidence and other independent experts to develop and implement community and stakeholder engagement plans in Phase 2. These plans will include an open, fair and public participation type methodology, to help ensure sites selected are both technically and politically acceptable. Section 3.2 gives further information on stakeholder and community engagement.

2.7.12 The Scottish Government will develop a detailed siting strategy during Phase 2 that takes due account of the wider stakeholder community and the national interest. This will be developed in line with international best practice and guidance. The siting strategy will address various topics including:

• a methodology for the decision on whether to build one or more disposal or storage facilities.
• the reuse of brownfield or derelict or contaminated land
• consideration of transport

Design and planning of a disposal site

2.7.13Under the current regulatory regime, waste can only be disposed of at a facility which is acceptable to the regulators. Such near-surface facilities designed to accept higher activity waste have not yet been built in Scotland.

2.7.14Disposal facilities need to be capable of existing for much longer time periods than storage facilities. The construction of any new near-surface disposal facility or radioactive waste store will require a developer to seek planning permission and have the requisite safety cases in place. Safety cases are required by ONR under a nuclear site's license conditions.

2.7.15Proposed disposal facilities will need to comply with the comprehensive guidance document "Near-surface Disposal Facilities on Land for Solid Radioactive Waste: Guidance on Requirements for Authorisation ( GRA) produced by the UK Environmental Regulators" ^[9] . The GRA uses a risk based approach to regulation and sets out a number of requirements that a developer must meet to obtain an authorisation for a disposal facility.

2.7.16 For a developer to operate a radioactive waste disposal facility, an environmental safety case will be required in order to obtain an authorisation from SEPA. Information on the regulatory and safety case process for higher activity waste can be obtained from ONR and SEPA. The case must demonstrate how the disposal of a specific radioactive waste inventory (the radionuclides in the waste, the total activity, activity concentrations, and physical and chemical forms) for a proposed facility design and location can meet all of the requirements in the GRA. The environmental safety case must demonstrate, amongst other things, that the facility can meet regulatory requirements regarding radiological risks to people and the environment.

2.7.17The Scottish Government expects developers to work closely with planning authorities and regulators in both the design and siting of disposal facilities for radioactive waste.

2.7.18In Phase 2 options for the design of a near-surface disposal facility will be ready. The design will need to identify clearly how monitoring will be undertaken and how waste packages will be retrieved, in line with requirements of the 2011 Policy. The developer will have to satisfy regulators as to their ability to meet health, safety, security and environmental requirements.

2.7.19The Scottish Government will monitor international progress in planning and developing near-surface facilities to learn from the experience of these programmes.

Summary of Phase 2

During Phase 2:

• The Scottish Government will develop and implement a community and stakeholder engagement plan and siting strategy to ensure effective and robust public engagement on the matter of HAW management.
• The Scottish Government will work with the NDA, other waste owners, suitable waste management organisations and regulators to help develop near-surface disposal concepts for waste suitable for this management route.
• Plans for the design, siting and construction of second generation storage facilities will be developed. Second generation stores are required for the safe and secure storage of HAW prior to future disposal facilities being commissioned.
• Plans for the design, siting and construction of near-surface disposal facilities will be developed. These facilities will be suitable for the disposal of a significant portion of HAW in Scotland.
• The NDA and the Scottish Government will devise a strategy for management options for HAW currently not understood as suitable for near-surface disposal.

Chapelcross

2.8 Phase 3: 2070 Onwards

Site status

Under current plans:

• Chapelcross/Hunterson A/Torness/Hunterston B : Will enter final decommissioning phases. Over 60% of the HAW in Scotland is expected to arise in this period. Actions will include safely dismantling the reactor vessels contained within the remaining reactor safestores, and ensuring safe and secure long term storage of disposal of the resulting waste. The estimated completion date for decommissioning all nuclear sites in Scotland is 2120.

2.8.1In Phase 3 second generation storage facilities planned during Phase 2 will be constructed for the storage of HAW prior to final disposal routes being available.

2.8.2Following the research and development programmes and the siting and design processes in Phases 1 and 2, it is anticipated that in Phase 3 construction of near-surface disposal facilities will begin. In Phase 3, the availability of disposal facilities will allow the disposal of reactor dismantlement waste without the need for a storage phase. The timely development of disposal facilities will also reduce the need for second generation storage facilities, that should only be needed for those wastes for which a near-surface disposal technology has not yet been identified.

2.8.3Wastes that are understood to be unsuitable for near-surface disposal, under available technologies, will still require on-going storage prior to a suitable waste disposal solution being selected in Phase 3. While this is an acceptable part of waste management, long-term storage does not mean indefinite storage but it may mean waste stored for many decades. It is anticipated that facilities for the management of these wastes will be constructed in Phase 3 upon review of the R&D programmes undertaken in the previous phases. It remains the objective of the Policy to ultimately identify disposal routes for all the wastes.

Research and development in Phase 3

2.8.4In Phase 3 the R&D programmes for the management of HAW currently understood to be unsuitable for near-surface disposal may continue on from Phase 2. It can be expected that the disposal technologies developed in Phase 2 for the wastes with greater potential for near-surface disposal under current understanding, and further experience in disposal methods around the world, will assist in the development of disposal options for the more challenging classes of waste.

2.8.5A final disposal route for these wastes will be selected during Phase 3 after careful analysis of R&D programme results and other factors including safety and environmental impacts.

Summary of Phase 3

During Phase 3:

• If applicable, R&D is undertaken in support of programmes to find waste management options for HAW, currently not understood as suitable for near-surface disposal, will continue.
• Second generation storage facilities will be constructed.
• Near-surface disposal facilities will be constructed.
• Final disposal routes for all HAW will be selected and implemented.

Artists Impression of the End State of the Dounreay Site