LLWR Managing Director’s Report to WCSSG October 2012-March 2013

Dennis Thompson Managing Director

WCSSG Scrutiny Report

OCTOBER 2012 TO MARCH 2013

Tuesday 7th May – Cleator Moor Civic and Masonic Centre

This report focuses on the past 6 months of operations at the Low Level Waste Repository and provides a brief 6 month look ahead. Highlights On Tuesday 26th March 2013, the contract extension for the Management and Operations of LLW Repository Ltd (LLWR) was signed by both the NDA and LLWR’s Parent Body Organisation, UK Nuclear Waste Management Ltd (UKNWM). We are pleased to report that we enter the second term with excellent statistics in both Safety and Delivery.

Our positive trend in Lost Time Accidents continues and the DACR and TRIR remain

at zero. During the period we achieved 500,000 hours without a lost time accident

which represents a major achievement for LLWR. This equates to 18 months without

a lost time accident.

On the 28th February 2013 we delivered LTP-13 on schedule. The joint assurance

reviews have confirmed that the plan represents a quality baseline against which

performance can be measured. The Performance Baseline has been approved, with

Contract Baseline approval from the NDA expected in the coming weeks following

close out of several actions.

Magazine 4 was declared to be at C0 levels on the 5th February 2013. Ventilation

removals have continued in parallel with forecast completion remaining on schedule.

This is a major milestone for LLWR and means that for the first time in decades,

personnel can enter the facility without requiring Air Fed Suits.

This financial year we have facilitated the diversion of 753m3 Combustible, 3,284te

Metallic (plus an additional 3,110te of Berkeley Boilers) and 1,657m3 of VLLW wastes.

Historically all of this waste would have been destined for the Repository,

unnecessarily taking up valuable disposal capacity at the LLWR Site.

The Second Lot of Berkeley Boilers were removed from the Magnox Site ahead of

schedule and were offloaded at the Studsvik Treatment Facility in Nykoping Sweden

on 31st March 2013.

Grouting Operations commenced during the period following an extended period of

outage. By the end of the year 247 ISO Freight containers had been grouted, 272

LLW REPOSITORY LTD

MANAGING DIRECTOR’S REPORT TO WCSSG

received and 613 remain ungrouted. The ungrouted stock will be worked off over the

next three years in line with LTP-13.

We have experienced several problems with our aging fleet of Forklift Lift Trucks (FLT)

during the period. The tender for the new FLT’s has been completed and an order

placed. The first new FLT is scheduled to arrive in September 2013.

Following the conclusion of the Tender Evaluation process for the PCM

Decommissioning and Demolition Framework, LLWR is pleased to announce NSG

Environmental as the Preferred Bidder. Once the contract has been let, mobilisation

will commence.

NSG are supported by their specialist subcontract partners Areva RMC, KDC

Contractors and RPS, together with key supply chain partners including Romar and

Speedy Hire Services. As they move forward into delivery, NSG will continue to

engage members of the local supply chain and draw upon the expertise within West

Cumbria to further strengthen their team. They will also recruit additional personnel

from the local labour pool to support with the delivery of works, offering new

opportunities together with support in skills development and the achievement of

career aspirations.

A revised Programme business case based on an accelerated six year programme

(instead of the 10 identified in LTP08), has been submitted to the NDA for

consideration and sanction.

Health, Safety, Security and Environment

The improved conventional safety performance continues with no reportable injuries or

significant near misses. The site DACR and TRIR are now both zero following an

accident free year, it is now over 550,000 hours since the last lost time accident at the

Site.

Accident Statistics, LLWR P60

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The LLWR Improvement Plan has made good progress in disciplined operations with

phase 1 nearing completion. Of the 200 activities identified for phase 1 approximately

180 are complete, including all activities for Alarm Management and Log Keeping

which were completed to programme by the end of March. The phase 2 aspects of

Disciplined Operations are in the final stages of baseline schedule production.

Delivery of this schedule will start in May and is scheduled for completion in October

2013.

In support of the LLWR improvement programme a Project Evaluation Board (PEB)

was undertaken in March 2013 by the Parent Body Organisation (PBO) as part of its

Assurance regime. The PEB Board members recognised the amount of work that has

already been undertaken at LLWR, and were very positive about the engagement and

motivation of the workforce to reach the standards set. As would be expected for a

review of this kind the PEB identified a number of areas of improvement which will be

incorporated into the Improvement Plan for 2013.

In the area of Emergency Arrangements, work continues to ready the site for moving

away from Sellafield Fire & Rescue, with the remaining work primarily focussed on

removing the reliance on Sellafield Fire & Rescue service for C5 entries. The target

date for all on-site arrangements to be completed is the end of April 2013. Once all

actions are complete, the site will then transition to the use of 999 calls. The Site is

working closely with the Nuclear Regulators and Cumbria fire service during this

transition to ensure the Cumbria Teams are fully familiar with the hazards on the Site

and can respond effectively.

Waste Management Services

You will recall early in 2012, LLWR worked with Magnox Ltd and the Supply Chain to

remove 5 of 15 boilers from the Berkeley Site. This multi-disciplinary pilot project was

delivered safely to time and cost. It paved the way for the second Lot of Berkeley

Boilers (10 in total) which were successfully removed from Berkeley Site ahead of

schedule and were offloaded at the Studsvik Treatment Facility in Nykoping Sweden

on 31st March 2013. The treatment and size reduction of all 15 boilers will see an

overall reduction of approximately 95% and result in the repatriation of treatment

residues from the process of potentially 5% Low Level Waste to the Repository.

In addition the recycling of the UK's metallic low level waste in Germany has resumed

following confirmation that appropriate insurance arrangements were in place at the

Siempelkamp GmbH site near Düsseldorf.

VLLW disposal to the commercial hazardous waste landfill sites operated by Augean

Plc (East Northamptonshire) and Sita UK Ltd (Lancashire) is underway. A number of

sites (including Sellafield Ltd) have now disposed of waste to these facilities. LLWR's

arrangements to 'channel' nuclear liability arising from these disposals are in place and

each consignment is managed accordingly.

Despite receiving 65 consignments in March (more than double the previous month),

the total number of containers received at the site in 2012/13 was 272. This compares

well with the 2011/12 total of 296 and continues the downward trend in disposals at the

LLWR site. Refer to Appendix 1.

Waste Treatment and Diversion Services:

Sellafield Ltd consigned their largest single item so far (24Te) without prior size

reduction. The item was transported to the Studsvik Metal Recycling facility at Lillyhall

near Workington as a wide load (under special transport arrangements). Sellafield Ltd

are also routinely consigning combustible and metallic waste via LLWR and have also

utilised LLWR's Transport service for the first time during this quarter.

Magnox Ltd continue to make good use of LLWR's waste services - all Magnox LLW

Transport is now provided by LLWR, the Berkeley site has placed several work

packages through the Waste Characterisation Service and multiple Magnox sites are

consigning metallic and combustible waste for treatment. VLLW has been shipped

from Trawsfyndd, Bradwell and Chapelcross for disposal during the period.

RSRL have successfully completed metallic, combustible and VLLW projects with

LLWR during the quarter. The teams involved met with senior managers from both

organisations in February for a useful discussion on future plans and ways that LLWR

could improve its services to Winfrith and Harwell.

Transport & Logistics Service:

The Transport Service is progressing well - the total number of shipments carried out

by the team since the service was launched in April 2012 is two hundred and sixty two.

This includes five train services (carrying multiple containers from multiple customer

sites). The utilisation of potential 'empty runs' remains high with almost 70% of

potential empty runs being utilised (e.g. for delivery of new containers). A new IT

application has been developed by LLWR to enable closer collaboration between

LLWR and Direct Rail Services Ltd and the consignors who are using the service.

Key Statistics

• 261 road and 5 rail shipments associated with treatment and disposal of waste through the LLWR / DRS transport service.

• Metallic waste treatment target has been exceeded – 3,284 tonnes (te) of the 2,748 te target treated by the end of March.

• Combustible waste treatment target has been exceeded – 753m3 of the 609m3 target treated by the end of March.

• VLLW disposal target is 80% complete – 1657m3 of the 2,084m3 target disposed by the end of March.

• LLW Disposal – 272 ISO containers (5,200m3) received by the end of March.

Container Services are also progressing well - two new designs of waste drums are

being supplied to customers to provide standardised containers for super compaction

and combustible waste services.

National Programme:

The second biannual National Programme Delivery Overview Group meeting was held

in Manchester in February to enable the dissemination and discussion of information

relating to the National Programme with an extended range of stakeholder including

NDA, SLCs (NDA and non-NDA), regulators, RWMD, DECC, NuLeaf and local

planning authorities.

A National Programme stakeholder survey has been undertaken involving interviews

with a range of key stakeholders to assess stakeholder perception of the National

Programme and their level of engagement with it. Feedback from this stakeholder

survey has been provided to the National Programme Office with recommendations to

address shortfalls and exploit opportunities presented. This feedback was presented

to the LLWR Working Group on the 25th April 2013. It is our intention to work with

Stakeholders to develop an action plan that will be presented to the next Delivery

Overview Group meeting in August. On that day attendees will determine key

priorities, how best to implement them and agree a timeframe for delivery.

Work on a range of diverse LLW management topics has continued during the period

including a guidance document on the decision-making factors for LLW / ILW cross-

boundary waste, developed in collaboration with SLCs and RWMD. An assessment of

VLLW arisings versus capacity has been finalised incorporating comments from local

authorities and the supply chain. This report is available on the LLWR web site.

Workshops have been held to initiate development of a LLW management Best

Practice Model to support the Peer Review Programme planned to commence in

2013/14. Collaborative work has been undertaken to support improvements to the

National Waste Inventory with a visit to Dounreay, to share best practice and to

provide feedback on priorities for UKRWI 2013, and a Joint Prioritisation Workshop

with RWMD and Urenco at Capenhurst.

The metrics for the treatment and diversion services appear in the dashboard

information at figures 1 and 2 overleaf.

Figure 1

Figure 2

Environmental Safety Case

The Environment Agency's review of the 2011 ESC has continued and further

information has been provided in response to Agency requests. Responses were

made to 17 Agency Issue Resolution Forms (IRFs) since my last report to the

WCSSG. These responses address a total of 34 individual questions, leaving only 12

IRFs outstanding. Discussions have begun with the Agency on our application for a

revised permit allowing for disposal of LLW.

Formal implementation of the 2011 ESC has begun, following the plan for

implementation delivered to the NDA at the end of 2012.

An investigation with respect to the container degradation and voidage has been

completed. It should be noted that this investigation has confirmed that the

assumptions made within the ESC remain valid with minor modifications to the Cap

design. An Action Plan was submitted to the Environment Agency at the end of March

2013. It outlines the plan to remove vegetation that has accumulated on the

containers and highlights the considerations for the accelerated closure of Vault 8.

The plan to Cap Vault 8 is not only dependent upon the container degradation issues

must also address the practicalities of higher stacking proposals and the extent to

which they can be implemented over the coming years while maintaining the integrity

of the existing disposals in line with best practice. We are currently undertaking

studies to inform the implementation of the closure works. These studies will be

complete within 12 months when we will be in a position to provide a detailed plan for

the closure of the Vault.

Work was completed on the assessment of the proposal to reuse low-activity material (VLLW) in the final cap profile against the requirements of the ESC. The assessment demonstrated that the proposal is feasible in terms of meeting the requirements of the ESC. Material acceptance requirements, covering both engineering properties and levels of radiological and non-radiological contamination, have been derived as part of the assessment. Further work still needs to be done to establish the logistics of implementing this type of project and identifying whether the forecast arisings fall in line with construction phases etc.

Work was begun on the development of a programme for monitoring the evolution and

performance of the engineered repository system as the closure engineering is

installed. Specification also began of the future programme for reducing uncertainty in

near-field understanding before the next major iteration of the ESC.

Minor and Reportable Events The following events were notified to ONR during the period: o While moving an ungrouted container within the Grouting Facility compound the

container was pierced by the forks of the Boss Fork Lift Truck. The Forks entered the container by approximately 150-200mm. The Team Leader was informed immediately and the forks were withdrawn. The forks, the container and

compound were all checked for release of contamination and none was found. It was confirmed that no material was released from the container nor was waste visible through the hole. Immediate repairs were made to the container using the RADSAFE emergency container repair equipment comprising a riveted aluminium plate and expanding foam. Learning from this event will be incorporated into relevant procedures and implemented.

o On 26th February 2013, low levels of contamination were found during routine

screening of a Studsvik worker at the Metals Recycling Facility at Lillyhall, Cumbria following size reduction of a Sellafield consignment of low level waste via the LLW Repository Ltd’s Framework service. The contamination was confined to the finger of one hand and was removed prior to the worker leaving the facility. Following this event, internal investigations were conducted by all three organisations to minimise the chances of future occurrences and incorporate learning from experience. The levels of contamination were below the reportable limits set by the Nuclear Regulator.

o On 12th November a member of staff reported hearing excessive air flow from the

cover of a secure off-site manhole. The manhole is associated with the marine

outfall pipeline which discharges water collected from the LLWR site. This water is

primarily rainwater and contains very little radioactivity. LLWR carried out

additional monitoring around the manhole. The results clearly demonstrate that

there is no detectable radiation or contamination in or around the manhole area.

The Company initiated a full investigation into this abnormal condition and

discovered that two air release valves had failed. These valves need to be

replaced and to do this access is required to the bottom of Manhole 11. Manhole

11 is approximately 14 metres deep and 2.4 metres wide with standing water

approximately 4.5 metres deep. Implementation plans to remove the water have

been developed and discussions are scheduled in early May with the landowner

and Natural England to allow access for the plant and machinery to extract the

water. The other air release valve is located in Manhole 3 which is much shallower

and has no standing water. Amendments to the pipework and replacement of the

valve will occur in May.

Looking Forward During the 2013-2014 financial year it is our intention to focus on the following:

• Achieving the Joint Waste Management Plan targets for waste diversion.

• Progressing Site Optimisation.

• A new framework contract for key waste treatment services using the government concepts on lean procurement.

• Delivering our Asset Refurbishment and Replacement Project.

• Taking the PCM Programme through sanction and delivering it to the accelerated schedule.

• Seeing the Improvement Plan through to its completion. • Working through the funding shortfall identified in this FY.

• Placement of Engineering Design and Construction Framework Contract.

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Appendix 1 – Waste Diversion 2008/09 to 20112/13