2.0 Land Quality Programme

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1 2.0 Land Quality Programme The Sellafield site has a legacy of ground contamination from its historical use as a Royal Ordnance factory and its subsequent development as a nuclear facility. The ground contamination consists of both radiological and non-radiological contaminants. These can be associated with the site s current use and also with the former Royal Ordnance factory. Contaminated land at the Sellafield site has been defined as an underground store of contaminants sourced from historic building leaks, inadvertent spills, and authorised disposal facilities and burial trenches. This definition has been agreed between Sellafield Ltd. and the Nuclear Installations Inspectorate to allow the land contamination beneath the site to be regulated and managed under similar principles as the other waste management processes on the site. The store of contaminants has the potential to increase in size through groundwater transport and migrate off-site to contaminate geologic materials underlying adjacent land not associated with the site. In December 2005, after consultation with EA and NII, Sellafield Ltd. formed the Contaminated Land Programme to provide for the integrated management of the Sellafield site contaminated land and groundwater. In 2008 this programme was renamed the Land Quality Programme. The Sellafield Ltd Land Quality Programme is organised within the Nuclear Decommissioning and Major Projects Group. Figure 2.1 provides an organogram of the Land Quality Programme team. 2.1 Groundwater Management Roles and Responsibilities Specific to groundwater management the Land Quality Programme team: owns and manages the Sellafield borehole groundwater monitoring network and sampling programme; evaluates and documents groundwater monitoring data to provide an understanding of the existing groundwater contamination underlying the Sellafield site; plans and implements groundwater characterisation studies to ensure the appropriate understanding of the subsurface environment; evaluates and documents hydrogeologic data and information to provide the most upto-date groundwater flow and contaminant transport conceptual models of the Sellafield site; develops and maintains Land Quality Programme groundwater management capabilities and intelligent customer functions; integrates and maintains appropriate groundwater data analyses tools such as GIS and numerical flow and transport models; develops and maintains appropriate groundwater data management systems. Implements internal and external stakeholder engagement related to groundwater management; and integrates groundwater management into the planning and prioritisation of remedial action. 2.2 Land Quality Strategy The primary objective of the Land Quality Programme strategy is to understand, control, and manage the legacy of contaminated land and groundwater at Sellafield to ensure protection of the work force, the public, and the environment. Due to the longevity of operations and decommissioning on the Sellafield Site there is a need to manage the subsurface legacy insitu at Sellafield for at least the next 40 years. Therefore the overall strategy is split into different timescales as the above-surface infrastructure is decommissioned. The 2007/2008 Page 15 of 144

2 Lifetime Plan identified the following key objectives and the planned time-frame to meet these objectives: Develop and implement a strategy to manage the existing disposal trenches within Separation Area ( ). Management control of existing groundwater contamination ( ). Treatment of existing sources of radioactivity in the ground ( ). Remediation of near-surface contaminated ground near or beneath buildings in conjunction with building decommissioning and demolition ( ). The Land Quality Programme short-term strategy is documented in Eilbeck (2006). Eilbeck (2006) provides the overarching strategy to manage contaminated land and groundwater for the short term (next 3 years) and describes how this will shape the medium-term strategy (3 to 10 years). The long term is seen as 10 years and longer and was formulated as part of the Programme Strategy 2005/06 deliverable (BNG, 2006). Figure 2.2 provides a schematic view of the linkage between the different time-frame strategies. During the short- to medium-term the key management objectives are to prevent an increase in the contaminated land inventory, and limit expansion of the contaminated land store. The work areas to support meeting these objectives include: Maintenance of the Contaminated Land Safety Case and Best Practicable Means (BPM) assessments to ensure doses to the workforce and the public are as low as reasonably achievable (ALARA). Best Practicable Environmental Option (BPEO) assessments to identify appropriate options for the management and control of the existing legacy contamination. Maintenance of a borehole monitoring programme to improve understanding of the contaminant transport attenuation and provide time series data. Leak Management and Detection Programme to ensure a minimal increase in the subsurface inventory. Characterisation Studies to ensure appropriate understanding of the subsurface environment and refine conceptual models of the site. Assessment studies to determine optimum management and remediation options to be implemented in the medium and long term. Remediation Programmes to implement appropriate remediation options. Development of the Land Quality Programme infrastructure (build and maintain a staff of appropriate Subject Matter Experts; maintenance of the intelligent customer base; acquisition and utilisation of hydrogeologic data analyses tools such as GIS and numerical models; and data/records management including environmental data management). Formulation and maintenance of internal and external stakeholder engagement plans. The short- to medium-term strategy summarised above represents the current iteration of the Land Quality Programme for the management of contaminated land. As on-going characterisation of the Sellafield site continues, new information and data will result in improved knowledge of the nature and extent of contamination in the subsurface. This improved knowledge is factored into annual strategy reviews to ensure that the current strategy remains appropriate. Atherton (2007b) documents the 2007 strategy review. 2.3 Leak Management and Detection Programme In order to fulfil its obligations for leak detection and management under the Nuclear Installations Act, Radioactive Substances Act, Environmental Protection Act, and the Energy Page 16 of 144

3 Act, Sellafield Ltd operates a comprehensive Leak Detection and Management Programme. The purpose of this Programme is to prevent, as far as reasonably practicable, further leaks to ground from the Sellafield Site. The programme includes the following aspects: Analysis of regulatory requirements, Relationship of leak detection with the Land Quality safety case, Evaluation of past leak source terms, Evaluation of known current leaks to ground, Evaluation and ranking of potential future plant leak source terms, Evaluation of potential drain system leak source terms, Interfaces and boundaries between Land Quality and other Sellafield plants and departments, Leak detection audit programme, Application and dissemination of leak detection technology, and Integration of groundwater monitoring boreholes in Leak Detection. The Sellafield Land Quality Programme serves as the integrator for this programme and provides expert support and oversight functions to the plants. The individual plants on site are responsible for the leak to ground hazard assessment and associated mitigation measures for their plants. Land Quality supports the plants in their efforts and ensures that the requirements are implemented appropriately through regular interfaces and audits. The groundwater management programme is closely tied to the leak detection and management efforts. The groundwater wells and statutory analytical results are utilised as supplemental monitoring points for leak detection and the nature and extent of the existing groundwater contamination is used to identify potential future leak sources and pathways. 2.4 Quality Framework The Land Quality Programme quality framework incorporates, at the highest level, the Sellafield Ltd Quality Assurance requirements. Two Land Quality Programme-specific initiatives have been completed within this framework. These initiatives included a BPM assessment of the management of contaminated land (Hullock, 2007) and a quality assurance programme plan (Sutton, 2007) that provides a roadmap focused on quality requirements for groundwater monitoring and sample analysis Best Practicable Means Assessment Concurrent with the development of the short- to medium-term strategy, the Land Quality Programme implemented an assessment to evaluate the application of Best Practicable Means (BPM) to manage contaminated land on the Sellafield site (Hullock, 2007). This BPM assessment was accomplished using the Sellafield Ltd Guidance on Best Practicable Means and Best Available Technique Assessment (SSP A, British Nuclear Group, September 2005). This guidance document was developed from the Environment Agency Operator and Polluter Appraisal guidance, and specific elements of the RSA 93 Certificate of Authorisation. This initial BPM assessment focused on leak detection as a process to minimise additions to existing contaminated land and groundwater monitoring as the method to monitor for potential changes to contaminated land. Where processes and/or controls were considered to be insufficient, recommendations were made for further improvements. The key recommendations specific to groundwater monitoring included: Page 17 of 144

4 Enhancing the analysis and interpretation of existing and future groundwater monitoring information to provide more information on the overall condition of the groundwater beneath the site. Development and incorporation of a more extensive programme of monitoring and analysis for non-radiological contamination into the groundwater monitoring programme. To address the first recommendation, the Land Quality Programme has enhanced the content of the Groundwater Annual Report (this document) to better reflect the overall condition of the groundwater beneath the site. In addition, the Land Quality Programme is working closely with the plant owners to develop groundwater sample data analysis protocols that better reflect the overall condition of the groundwater beneath individual plant sites. The second recommendation has also been addressed with the initiation of a Pollution Prevention Control (PPC) sampling programme in 2008/2009 (see Section 5). In addition, the BPM assessment recommended periodic reviews of Land Quality Programme BPM implementation to identify opportunities for continuous improvement as new information becomes available. This recommendation has been accepted and the Land Quality Programme has committed to assess its BPM implementation across the Programme every three years. The next BPM assessment is scheduled for completion at the end 2009/2010. There are multiple 2008/2009 task plans which will contribute to enhancing the Land Quality Programme s implementation of BPM specific to groundwater monitoring (see Sections 4.7, 7.1 and 7.2). The work on these task plans is informed by appropriate industry best practices and regulator guidance. In relation to industry best practice, Sellafield Ltd and individual Land Quality team members are members of the SAFEGROUNDS Learning Network. SAFEGROUNDS provides a forum for developing good practice guidance on the management of contaminated land on nuclear and defence sites in the UK. Through this membership the Land Quality Programme keeps abreast of industry best practices, and contributes appropriate lessons learned into best practice guidelines of the SAFEGROUNDS Learning Network Quality Assurance Programme Plan Land Quality developed a quality assurance programme plan specific to groundwater monitoring (Sutton, 2007). This plan has the structure of ISO 9001:2000, and there is a near one-to-one correspondence between the subheadings in ISO 9001:2000 and the subheadings in this plan. Some differences occur simply because ISO 9001:2000 is a general requirements document, and this plan is a specific requirements document for a specific programme. The primary quality objectives addressed by this plan are to: Ensure data are traceable and fit for purpose. Ensure samples are representative. Ensure boreholes and monitoring wells meet quality requirements. Ensure that data interpretations are clear and understandable and communicated appropriately to Regulators and Stakeholders. Ensure that data and information are managed to assure their integrity and security. This plan is focused on groundwater monitoring. However, it also incorporates quality goals for a wide range of Land Quality work elements and processes. These include operations, and strategic planning; customer focus, control of work processes, documentation and record keeping, management of electronic data and records, development and control of processes Page 18 of 144

5 to ensure data quality and traceability, adequacy of resources including intelligent customer capability, and feedback and improvement. This plan is primarily a guidance document. As a guidance document it incorporates BPM for groundwater monitoring and provides a strong foundation for establishing quality requirements for the Land Quality Programme. However, the plan explicitly identified the need for developing implementation requirements that are consistent with and integrated into the Sellafield Ltd quality assurance framework and quality processes. Guidance and corrective actions to accomplish this are being developed as part of an on-going quality framework review being carried out by representatives of the Sellafield Ltd Quality assurance organisation. The outcomes from this review will be reported to the Regulators by the end of September 2008, and identified quality improvement initiatives will be integrated into on-going 2008/2009 work and work planning for 2009/ Stakeholder Engagement The Land Quality Programme maintains direct engagement with a large number of internal and external stakeholders that have an interest in, are affected by, or could affect the operations conducted by the Land Quality team. Key elements of this engagement include groundwater management and groundwater monitoring. The major stakeholders groups and the terms of engagement with them are documented in Ostridge and Spencer (2008). These major stakeholder groups include: Nuclear Decommissioning Authority (NDA) Sellafield site Internal Stakeholders Regulators External Stakeholders NDA Sellafield holds the site licence for the NDA. Thus, the NDA is a critical stakeholder for all work undertaken on the Sellafield site. In order to ensure progression of work the Land Quality Programme is required to demonstrate to the NDA that the project is being carried out in a safe, professional, and cost effective manner. This is accomplished through regular updates to the NDA programme manager provided by the Land Quality Programme manager. These updates address programme performance and the timely identification of issues or concerns Sellafield Site Sellafield site stakeholders include individual plants and construction projects, functional organisations, and infrastructure organisations. In the area of groundwater management the Land Quality Programme is implementing coordination with Sellafield site plant owners in the areas of plant leak detection including managing independent assessments of plant leak detection arrangements. In addition, the Land Quality team has developed formal agreements to support several individual plants in the evaluation of the present status of groundwater quality in monitoring boreholes in the vicinity of the individual plants. Elements of groundwater management are supported by other Sellafield site groups. These Sellafield site groups include the Analytical Services Department which provides the interface with external laboratories for groundwater sample analyses and the ESH&Q Environmental Monitoring and Assessment group which provides support for groundwater sampling. Page 19 of 144

6 The UKAEA Windscale site is an additional site stakeholder. In 2008 the UKAEA site licence was transferred to Sellafield Ltd. This transfer included a 5 year transition period during which time Windscale management will be integrated into Sellafield Ltd. The Land Quality Programme is actively involved in this transition through integration with the Windscale Environmental organisation Regulators The Environmental Agency (EA) is the lead site regulator with respect to Environmental legislation under the Radioactive Substances Act (RSA) 1990 and Environment Act 1990 (as amended). The main philosophy of these regulations is the protection of the environment (preventing any further deterioration) so that it is a resource for future generations. The EA therefore has an interest in contaminated land and groundwater, waste management and discharges to the environment which it regulates through the PPC Permit, RSA authorisation and waste management licences. The Sellafield Site groundwater monitoring programme is agreed with the EA each year and is documented in the Compilation of Environment Agency Requirements. The monitoring of radionuclides by the programme aids the site s compliance with its RSA authorisation as it can be used to demonstrate that there are no unauthorised discharges from plants as well as allowing any expansion of contaminated land to be identified. The non-radiological monitoring aids compliance with the PPC permit by confirming the effectiveness of the pollution prevention measures on the site. The Nuclear Installation Inspectorate (NII) regulates the site under the nuclear site licence. With regard to contaminated land this relates to the control of radioactive materials (and wastes). Contaminated land is managed as a store of radioactive material under the control of a Safety Case. The groundwater monitoring programme is an important element of the safety case. It provides a method for monitoring the waste store and provides information to characterise its content. The importance of the programme is demonstrated by the classification of the boreholes as Safety Related Equipment. As with the EA, the NII are involved in the yearly agreement of the groundwater monitoring programme. The Land Quality Programme team hold regular meetings with its regulators including quarterly technical meetings addressing groundwater management issues. These meetings allow the measurement of progress on regulatory issues and a mechanism for the regulators to discuss the development of the Land Quality Programme. As part of the regulator interface in 2008/2009, EA and NII carried out a joint inspection of the contaminated land and groundwater management arrangements at Sellafield. This inspection focused on the Sellafield Contaminated Land and Groundwater Management Project and broader issues such as groundwater monitoring protocols. The overall scope for this inspection included: Management arrangements. Waste disposition. Sampling & analysis. Records. Leak detection. Drilling operations. This inspection was completed in July Early feed-back from EA and NII was provided to the Land Quality Programme in August and the report documenting identified Page 20 of 144

7 issues/recommendations will be provided later in the year. The Land Quality Programme will incorporate the improvement requirements documented in this report into its on-going 2008/2009 work and into its task planning for 2009/ External Stakeholders It is recognised that the activities of the Land Quality Programme are of interest to many and varied external stakeholders. The spectrum covered by these external stakeholders includes: local borough and parish councils (e.g. Copeland Borough council and the Gosforth Parish council), the West Cumbria Sites Stakeholder Group (WCSSG), pressure groups such as Cumbrians Opposed to a Radioactive Environment (CORE), environmental and decommissioning industry forums for best practices and technical dialogue (e.g. the SAFEGROUNDS Learning Network) local and national media, and Sellafield site personnel. Engagement with these stakeholders is managed by the Nuclear Decommissioning and Major Projects Group communications manager and the Sellafield Site Stakeholders relations group. An example of the Land Quality Programme s engagement with external stakeholders is their participation in the WCSSG Environmental Health Subcommittee s yearly meetings to discuss environmental issues associated with the Sellafield and Low Level Waste Repository sites. These meetings are open to the public and have a membership list including representatives of the sites, the local authorities, Health Protection Agency, National Farmers Union, the NII and EA as well as independent experts. The meetings are a forum for the discussion of environmental issues associated with the site and each year the annual Sellafield site groundwater report (this document) is presented. In 2008 the Land Quality Programme engaged with a new stakeholder. This stakeholder is the Land Quality Peer Review Panel (LQPRP). The LQPRP was set up to independently assess the management of contaminated land and groundwater at Sellafield. The panel has been involved with the development of the groundwater annual report (this document) in both the scoping phase and as a reviewer of the draft report Land Quality Programme Web Site To improve its external communication and coordination the Land Quality Programme initiated the development of a portal on the Sellafield Ltd. public internet website. This website opened in July Pages on the Land Quality website give a background to the Sellafield site, its setting and history, the current understanding of the land quality, the management approach and the current programme of work. Links are provided to relevant reports. As work progresses, new information or plans for future work will be placed on News pages and opportunities provided for comment or feedback. Links are also given to other websites and sources of supporting information. This website can be accessed at Page 21 of 144

8 2.6 Current Work Areas to Advance Groundwater Management There are eight key work areas related to groundwater management currently being addressed by the Land Quality programme. These include: Ensuring that the programme management quality infrastructure effectively integrates all Regulatory and Sellafield Ltd requirements. Establishing formal integration with Sellafield Plant owners to provide relevant groundwater sample analyses support and raise awareness on potential impacts of plant leaks on groundwater contamination. Compiling and migrating the numerous historical contaminated land and groundwater data into a quality assured data management system. Advancing the technical foundations underpinning the Sellafield site conceptual models through the acquisition and analyses of new and historic data. Initiating the Site Protection and Monitoring Programme (SPMP) identifying the site s data collection programme to support the Integrated Pollution Prevention and Control (IPPC) permit. Managing the Compilation of Environmental Agency Requirements (CEAR) groundwater monitoring programme. Evaluating and upgrading the existing groundwater monitoring borehole assets to enhance the acquisition of high quality groundwater samples. Enhancing the existing approach to stakeholder interactions. 2008/2009 task plans addressing these work areas are identified in Sections 2.7, 3.6, 4.7, and 5.5. Progress on these tasks is summarised in Section /2009 Task Plans Addressing Land Quality Programme Management Arrangements Two key 2008/2009 tasks were developed and are currently being implemented to ensure the continuous improvement in overall programme management. Table 2.2 summarises these tasks. Table /2009 tasks addressing programme management Task Independent Sellafield Ltd Investigation of the Land Quality Programmatic Framework Optioneering for a Contaminated Land Remediation Strategy Scope of Work The scope of this investigation included management and quality systems, organisational structure, resources and supervision, and audit arrangements, and extended to projects and work areas such as groundwater monitoring. This investigation was carried out by representatives of the Sellafield Ltd Quality Assurance organisation and completed in September The outcomes from this investigation will inform on-going 2008/2009 work and work planning for 2009/2010. The scope of this task is to produce preliminary updated versions of both the Contaminated Land Strategy and the Land Quality BPEO Plan documents for submittal to the Regulators (EA, NII, local authorities and NDA). This plan is consistent with guidance set out in Sellafield Procedure SSP 2.09A Best practice guidance note for decision making relating to optimisation of environmental discharges and disposals. Page 22 of 144

9 Section 2.0 Figures

10 Head of Programme Delivery Land Quality Business Support Delivery Manager Operations Technical Manager Programme Delivery Groundwater Manager Project Manager Sellafield Land Quality & Groundwater Project Figure 2-1 Organogram of the Sellafield Land Quality team Page 23 of 144

11 Figure 2.2 Schematic Diagram showing the Generalised Linkage between the Short-, Medium-, and Long-term Land Quality Strategies (White boxes = short-term; yellow box = medium-term; and green boxes = long-term) Page 24 of 144

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