URENCO Capenhurst Site Integrated Waste Strategy. URENCO UK Limited

URENCO Capenhurst Site Integrated Waste Strategy URENCO UK Limited 1

Executive Summary This document describes the URENCO Integrated Waste Strategy (IWS) for managing radioactive and non-radioactive wastes at the URENCO site at Capenhurst. It covers wastes currently on the Capenhurst site and wastes that will be produced by future operations. The URENCO site at Capenhurst comprises URENCO UK Limited (UUK), the holder of a nuclear site licence and environmental permits, and a number of tenants, some of whom are also in possession of an environmental permits. The tenants holding environmental permits are Capenhurst Nuclear Services Limited (CNS) and URENCO Chemplants Limited (UCP). A third tenant (Enrichment Technology UK ETUK) also resides as a tenant on the site but operates under UUK s environmental permits. It is a regulatory expectation of the Office for Nuclear Regulation (ONR) that licensees develop an IWS. It is also a regulatory expectation of the Environment Agency (EA) that Permit holders develop an IWS. In view of this, the Capenhurst Site has developed a joint IWS and UUK as licensee, has taken the lead in coordinating its production. The IWS is aligned with the seven topic areas outlined in the Nuclear Decommissioning Authority s (NDA) guidance ENG01. The Capenhurst site does not store or generate higher activity waste and therefore the joint guidance issued by ONR and the Environment Agency is not applicable (and hence a Radioactive Waste Management Case is not required). The IWS summarises the key waste management strategies for both radioactive and non-radioactive wastes, waste management opportunities and risks. In addition to wastes, the IWS includes an overview of the types of residues generated by URENCO at the Capenhurst site. The IWS outlines the current waste management practices and looks ahead to define where the site wants to get to, how we will get there and the key milestones for the short, medium and longer term periods. A key to a successful IWS is early regulator and stakeholder communication and engagement. An Action Plan has been compiled that develops a forward programme of work. This assigns responsibilities and completion dates for a set of objectives and actions. The key elements of the integrated waste strategy are that: it applies to the whole Capenhurst Site. it is aligned with the Waste Management Hierarchy and Best Available Techniques (BAT). it is consistent with the National Low Level Waste Management programme. It prioritises hazards and identifies how risks will be reduced. waste management awareness and waste management training is provided. present and future arisings of waste are managed. legacy Wastes are managed. URENCO UK Limited 2

Contents Executive Summary 2 1 INTRODUCTION 4 1.1 Background 4 1.2 Purpose 6 1.3 Scope 6 2 COMMUNICATION AND CONSULTATION 7 2.1 Regulatory input and consultation 7 2.2 Stakeholder input and consultation 7 2.3 Best Available Techniques (BAT) 7 2.4 Accessibility 8 3 OBJECTIVES AND AIMS 9 3.1 Where are we? Where are we going? 9 3.2 Setting Objectives 15 3.3 The Waste Hierachy 16 3.4 Interaction with other strategies and plans 18 4 DATA GATHERING 19 4.1 What Wastes Do We Generate At Present? 19 4.2 What Wastes Will We Generate In The Strategy Period? 19 5 CRITICAL EVALUATION OF WASTE MANAGEMENT OPTIONS 20 5.1 What Do We Do At Present? 20 5.2 What Will Be Needed In The Future? 21 5.3 Are Existing routes And Plans Satisfactory? 21 6 HORIZON 22 6.1 Key Deliverables, Decisions and Required Timescales For Delivery 22 6.2 Threats (risks) and Opportunity Management in Strategy Delivery 22 6.3 Action Planning 23 7 MONITORING AND EVALUATION 24 7.1 IWS review cycle 24 7.2 Indicators and metrics 24 7.3 Reporting and auditing 25 8 ACRONYMS 26 9 REFERENCES 27 URENCO UK Limited 3

1 Introduction This Integrated Waste Strategy (IWS) has been prepared by URENCO and it describes waste management strategies for operations at the Capenhurst Site, near Chester. This IWS is part of the company s commitment to demonstrate and communicate an integrated and sustainable waste management strategy for all URENCO operations on the Capenhurst site. URENCO generates radioactive and non-radioactive wastes and in the future new sources of waste will arise as new plant is commissioned or old plant is decommissioned. These wastes are managed in compliance with Environmental permits, the Nuclear Site Licence and other regulatory requirements. For radioactive wastes, a Corporate Radioactive Waste Advisor (CRWA) scheme (ref 1) has been established to ensure knowledgeable, experienced and competent personnel are available to provide advice on radioactive waste management and environmental radiation protection. As part of the CRWA arrangements, similar procedures are used by the four companies to encourage consistency across the site. 1.1 Background URENCO Limited is an international energy and technology group operating uranium enrichment plants in the United Kingdom, Netherlands, Germany and United States. The company s primary focus is on providing safe, cost effective and reliable uranium enrichment services for civil power generation within a framework of environmental, social and corporate responsibility. In the UK, the operator of the URENCO enrichment plants at Capenhurst is URENCO UK Limited. The relationships within the URENCO group are illustrated in Figure 1. Figure 1: URENCO Organisational Structure URENCO UK Limited 4

Capenhurst Nuclear Services Limited (CNS) is a subsidiary business of URENCO Ltd and a tenant on the UUK licensed site. CNS is a company specialising in uranic material management, decommissioning and recycling activities. CNS has recently taken over the contract to manage uranic materials and decommissioning activities from previous site operators, and delivers this work on behalf of the Nuclear Decommissioning Authority (NDA). CNS is developing a new Legacy Cylinder Facility (LCF) to manage its legacy stocks of NDA owned Uranium Hexafluoride (UF 6 ). Other URENCO group tenants on the site include URENCO ChemPlants Limited (UCP) which is currently designing and building the Tails Management Facility (TMF), a facility onsite for the management of UF 6 tails (i.e. a uranium co-product of enrichment with some viable U235 resource remaining). It is anticipated that this facility will become operational in 2016. This facility will deconvert UF 6 to Uranium Oxide (U 3 O 8 ) to allow the uranium to be stored in a more chemically stable oxide form for potential future reuse in the nuclear fuel cycle. A by-product of the deconversion process will be Hydrofluoric Acid (HF) and this will be recovered for reuse in the chemicals industry. Enrichment Technology UK Limited (ET UK), a subsidiary of the Enrichment Technology Company Limited (ETC), runs a small development and qualification facility on the site and a project office. It operates within the requirements of the UUK environmental permits. The Capenhurst site is a single nuclear licensed site, licensed under the Nuclear Installations Act 1965 (as amended) (NIA65) to UUK and operating under the regulatory requirements and permits/licence issued by the Office for Nuclear Regulation (ONR) and the Environment Agency. Although operating on the same nuclear licensed site, the UUK, CNS and UCP businesses all have separate Environmental Permits granted by the Environment Agency under the Environmental Permitting Regulations 2010 (as amended) (EPR 10). For the purpose of this document, UUK, CNS, UCP and ETUK will be referred to collectively as URENCO or the URENCO group. URENCO UK Limited 5

1.2 Purpose This document has been produced as part of URENCO s commitment to demonstrate and communicate an integrated and sustainable waste management programme at the Capenhurst site. This IWS presents the current strategy for managing radioactive and non-radioactive solid, gaseous and liquid wastes generated by URENCO at Capenhurst. The information in this document aligns with the URENCO Limited strategies and policies and is used to support onsite environmental and waste activities, waste disposals and future applications for Environmental Permits. There is an expectation from both the Environment Agency (e.g. as set out in the Nuclear Sector Plan) and ONR that nuclear licensed sites will maintain an IWS. This IWS follows the format and guidance published by the NDA (ref 2) which URENCO has adopted as good practice in the UK nuclear sector. This document supports compliance with environmental permits where an IWS is required in addition to Nuclear Site Licence Conditions 32 and 34. Through the IWS, systems are put in place for planning the effective management of wastes and to demonstrate compliance with regulatory expectations. 1.3 Scope This document defines the waste management strategies for all URENCO operations at the Capenhurst site. The strategy recognises the requirements of current legislation, regulatory requirements, government policies and national strategy as well as URENCO permits, licences and environment, health and safety policies and industry good practice. This document serves as a high level waste strategy and does not provide detailed information regarding individual waste streams, specific management arrangements and methodologies associated with the individual wastes; nor does it identify specific disposal routes. In addition to wastes, the IWS includes an overview of the types of residues generated by URENCO at the Capenhurst site. URENCO classifies residues as radioactive materials where the Uranium may be recovered back into the nuclear fuel cycle. This strategy describes where waste and residue management arrangements at Capenhurst are today, where the site wants to get to and what actions are required to get there. It applies to legacy wastes, operational wastes and residues, and future arisings. Waste and residue management arrangements within URENCO provide more specific and detailed inventories and procedures. This document focuses on communicating the site waste management strategy to both internal and external stakeholders. An Action Plan has been developed in conjunction with this IWS to describe near term activities that need to be addressed. Action owners and target completion dates have been assigned. The Action Plan is a separate live document and will be routinely monitored during quarterly meetings by representatives from each of the URENCO companies to ensure progress is being made and target dates are being met. The plan will be updated on an annual basis unless new activities require a shorter timescale. URENCO UK Limited 6

2 Communication and Consultation URENCO s aim is to ensure that operations at the Capenhurst site are understood and supported by the regulators, local community and other stakeholders. Our communication strategy identifies the regulators, stakeholders and special interest groups and their areas of site interest. The objective of our communications programme is to ensure that all interested parties are engaged early and provided with current, factual and relevant information in a timely manner. Where appropriate, progress against the delivery of the plan will be communicated both internally and externally on a routine basis. A Regulatory and Stakeholder Communication Plan will be developed that defines the engagement process and communication strategy for URENCO. 2.1 Regulatory Input and Consultation URENCO meets with both the Environment Agency and ONR frequently to discuss aspects of site operations, including waste management. When appropriate, meetings, including attendance by tenant representatives, are organised by URENCO to ensure a coordinated approach to regulatory engagement and provide information on site waste management activities. 2.2 Stakeholder Input and Consultation URENCO engages with internal and external stakeholders as interested parties on a routine basis. An increased use of social media to engage in two-way dialogue with our local communities has proven successful and our internet site offers a virtual tour of our enrichment facilities which has proven to be an effective means of communication. Routine examples of stakeholder engagement include: Local Liaison Committee meetings that are held on a six monthly basis and include updates on performance of operations including progress on waste disposals and residues etc. URENCO attends the quarterly Parish Council Meetings. General updates are provided and this may focus upon hazard reduction activities such as waste disposals, operations, residues shipments etc. Engagement with our internal stakeholders (e.g. employees and contractors) is also critical to our business as a means of maintaining awareness and involvement in site waste management activities. Several communications tools are utilised including the quarterly About U magazine, messages posted on information screens located throughout the site, a weekly podcast (which includes interviews with a spectrum of employees, including members of the Lead Team) and also by using the Company intranet portal. URENCO also engages with government and international organisations such as the World Nuclear Association, Nuclear Industry Association, and European Nuclear Society through site visits, meetings and structured communications through URENCO s Joint Committee. URENCO is also a member of the Nuclear Industry Liaison Group and the Nuclear Waste Research Forum which is a cross-industry group that aims to enhance coordination of research and development across UK site restoration and integrated waste management activities. 2.3 Best Available Techniques (BAT) In compliance with the Environmental Permitting Regulations 2010 (EPR 10) and nuclear industry guidance for BAT, URENCO uses a BAT assessment process to identify the best available methods and techniques to minimise waste, discharges and emissions. Available techniques and methods are aligned with the waste hierarchy and assessed via transparent, logical, systematic and auditable processes that balance the benefits of the process/ activity on the environment, workforce and public health against the cost and practicability of implementing the option. URENCO UK Limited 7

URENCO procedures that describe how to carry out a BAT assessment reflect the guidance and best practices included in the Nuclear Industry Code of Practice on BAT (NICoP) (ref 3). Regulators are informed of strategic option studies being undertaken and may be invited to observe and/or participate in the process. For example, in 2011 UUK produced a Best Available Techniques (BAT) document for UUK generated process materials and radioactive solid, liquid and gaseous wastes (ref 4) which was presented to both the ONR and the Environment Agency. Similar documents exist for CNS. The implementation of BAT has been a key consideration throughout the design process of the TMF. This is demonstrated within a suite of Best Practicable Environmental Options (BPEO) studies for the proposed activities. Optimisation of the preferred options is taking place during the design phase to ensure the finished plant operates using BAT. The primary goal is to maximise the opportunity to recycle uranium back into the nuclear fuel chain and to minimise the disposal of radioactive waste through decontamination of contaminated materials for reuse. For any new waste streams, gap analysis will be carried out to ensure the strategy aligns appropriately with the proposal. It is recognised that in some instances it may be prudent to complete a new study. 2.4 Accessibility This IWS is not protectively marked and publically accessible. Copies are available via the URENCO website (www.urenco.com). URENCO UK Limited 8

3 Objectives and Aims The aim of our IWS is to provide a common strategy basis and integrated approach for waste management on the Capenhurst site to ensure: Continued protection of the workforce, public and the environment through responsible construction, operation, decommissioning and waste management activities. All wastes are managed in a safe and responsible manner and waste management activities are implemented using good industry standards with a focus on hazard reduction. Common waste management objectives are set. Common approaches to waste management are adopted. Waste management and disposal routes are identified and available for all waste streams. BAT is applied for all waste management activities to ensure compliance with the waste hierarchy. Effective and timely regulatory and stakeholder engagement. Lessons learned are used to identify weak or non-compliant areas of work and processes, and action is taken to ensure repeat occurrences are prevented. 3.1 Where are we? Where are we going? The strategy contained in this IWS considers the lifetime of the site but focuses in detail on the period of 2014 to 2016. At the end of this three year period, the IWS will be reviewed in its entirety and revised to reflect the current status at the time. In addition to the IWS, a site decommissioning plan will be developed during 2014, which will identify waste management activities as the result of on-site decommissioning projects. The following summarises the waste types generated: Intermediate Level Waste (ILW) - Wastes exceeding the upper boundaries for LLW (see below), but do not generate enough heat to require special storage or disposal facilities. Low Level Waste (LLW) Wastes having a radioactive content not exceeding 4 GBq (Gigabecquerels) of alpha activity per tonne, or 12 GBq of beta/gamma activity per tonne. Low Activity Low Level Waste (LA-LLW) - A subset of LLW with an activity <200 MBq per tonne. VLLW A subset of LLW with maximum concentrations of 4 MBq (Megabecquerels) of alpha activity per tonne that can be disposed to specified landfill sites. There is an additional limit for tritium in such wastes. URENCO UK Limited 9

Out of Scope An article or substance that is not radioactive as defined in EPR10. These wastes are not subject to any radioactive regulation requirements but do remain subject to other relevant waste legislation. Hazardous Waste Controlled waste that contains any substance specified in the Hazardous Waste (England and Wales) Regulations 2005. These include oils, acids, specific metals and other materials including asbestos. Non-radioactive (general) waste Controlled waste which is not covered by the definition of hazardous or radiological waste, but which remains biologically, chemically or physically active if disposed to landfill. These include metal, timber, and other organic wastes. No hazardous wastes usually result from the general site activities (e.g. office, kitchen, canteen and general operational waste). URENCO generates radioactive and non-radioactive wastes and uranic residues as the result of site operations. Tables 1 and 2 summarise the current status of where URENCO is now regarding residues and radioactive/ nonradioactive wastes and the projection of future arisings. URENCO UK Limited 10

Table 1 Radioactive Waste and Residues Inventory Summary Current Waste Inventory Current Residues Inventory Future Projected Arisings UUK (inc ET UK) CNS ILW filter material Combustible low activity LLW solids Super-compactable LLW Absorber material (active carbon) Contaminated soils and other inert materials VLLW and LA-LLW Metallic waste Empty Type 30B UF6 Cylinders Combustible non-aqueous liquid Liquid scintillant Sources Waste awaiting characterisation Metals Redundant cylinders Pipe sections from building decommissioning Liquids Water from floor cleaning & slab remediation Oils and chemicals Solid VLLW Building slab rubble Used PPE & cleaning materials Silt from slab remediation & drains clean out Wood from scaffolding, cabins etc Absorber material Synthetic PFPE Oil Residues (uranic wipes, uranic breakdown, citric acid) Uranic decommissioning residues HF Liquors from cylinder wash-out As current plus: Metals Non-leachable/non-combustible VLLW/LA-LLW Empty Type 48Y UF 6 Cylinders As current plus: Metals Metal from demolition of building structures Liquids Liquors from cylinder wash-out Solid VLLW/LLW/Residues Silt from drains clean out Asbestos from redundant facilities Solid material from decommissioning buildings Chemical traps and other material from cylinder washing process UCP None None Liquids Contaminated HF acid Sludges Solid VLLW/LLW/Residues Radioactive and non-radioactive combustible/compactable wastes Non-leachable/non-combustible VLLW/LA-LLW Leachable non-combustible VLLW/LA-LLW Encapsulated wastes generated from processing NaDU Residue Filter material (e.g. MgF 2 and metal filter cartridges) URENCO UK Limited 11

Table 2 Non-Radioactive (Hazardous and Non-hazardous) Waste Arisings Summary Current Hazardous Waste Arisings Current Non-Hazardous Waste Arisings Future Projected Arisings Generated by all 4 Companies Waste electrical and electronic equipment Oils and chemicals (including solvents) Fluorescent tubes and batteries (heavy metals) Aerosol cans Clinical wastes Cardboard Glass Metals including cans/tins Paper Plastic Textiles Wood DECW* Food Waste Cooking oils As columns 1 and 2 plus: Asbestos and asbestos contaminated material (from CNS and UUK decommissioning activities) *DECW Demolition, Excavation and Construction Wastes URENCO UK Limited (Including ET UK) Residues Residue streams are not considered wastes. As shown in Table 1 above, UUK generates multiple residues streams as the result of its uranium enrichment processes. Some Sodium Fluoride/Alumina residues, laboratory effluents and citric acid are currently sent for Uranium recovery. Other residues currently remain on site pending ONR approval of the type 3516B package to transport these materials to a third party for recovery. UUK currently is planning to recommence operating the Perfluorinated polyether (PFPE) oil recovery rig operations in early 2014 to recover residue (PFPE) lubricant oils. Solid Radioactive Waste UUK currently has legacy and operational wastes stored onsite. Legacy wastes arose when certain waste disposal routes became unavailable. Through the Legacy Waste Project, UUK is committed to taking a vigorous and proactive approach to onsite management of waste whilst opening new disposal routes for offsite disposal. The potential disposal routes for these wastes include recycling, incineration, land disposal and release as out of scope waste, priority being given to waste minimisation and diversion from landfill. A BAT assessment has been prepared to support the Legacy Waste Project for solid legacy waste and it identifies the preferred disposal options for the different waste streams that will be generated. Gaseous Radioactive Waste Gaseous radioactive effluents arise from enrichment and laboratory activities and are discharged in compliance with site discharge permit requirements. Stacks are fitted with either a High Efficiency Particulate Air (HEPA) filter system or a wet venturi scrubber to minimise discharges. URENCO UK Limited 12

Aqueous Radioactive Waste Aqueous effluents are generated from UUK enrichment plant steam chest condensate, wet scrubbers, floor washings and from the Chemistry Services Department (CSD). For bulk radioactive liquid effluent, the volume of liquid transferred is minimised by collecting all radioactive aqueous liquid waste (or potentially contaminated water) in covered or indoor tanks, before being sampled and transferred for discharge. This prevents the ingress of rainwater or other liquors. The site Decontamination Facility operates processes that have removed the requirement for an additional liquid discharge. These include the use of a counter-current flow on the decontamination train (which enables the use of mildly contaminated rinse waters to be used to top up evaporative losses in the preceding tank within the decontamination train) and the use of dry ice (Carbon Dioxide pellets) to decontaminate components. Additionally, effluents and residues containing recoverable levels of uranium are collected for uranium recovery (see residues above), thereby avoiding unnecessary discharges. Non-aqueous Radioactive Liquid Waste Non-aqueous radioactive waste includes: Pump lubricants. o PFPE pump lubricant oil (previously processed on-site for oil recovery); spent hydrocarbon oil (arising from vacuum pump use prior to 10 years ago and now replaced by PFPE oil). o Terminal Valve Test (TVT) rig hydrocarbon lubricant oil with uranium contamination that cannot be reused or treated on site. Contaminated scintillant that cannot be treated on-site. Non-Radioactive Solid Wastes All office wastes, canteen wastes, maintenance and general operational wastes, including hazardous materials, are managed by a facilities management contractor. They are transferred to a registered waste broker for recycling, recovery or disposal to landfill where recycling or recovery cannot be achieved. Again, preferred disposal options are identified during optioneering. There are no legacy wastes stored on site. Non-radioactive Gaseous Effluents UUK has an Environmental Permit (ref 5) for the discharge of gaseous effluent from 21 discharge points across the site. Point source chemical emissions to air produced during enrichment operations at the UUK site are relatively low hazard and are primarily limited to Hydrogen Fluoride releases from the enrichment plant Gaseous Effluent Vent Systems (GEVS). Non-Radioactive Liquid Effluents UUK has an Environmental Permit for the discharge of liquid effluent from nine discharge points on-site. Four points discharge directly to the site surface water network and five discharge points flow to the on-site sewage effluent treatment plant operated by UUK. All these discharges flow into a culvert which leads to Rivacre Brook and ultimately to the River Mersey. Water used across the Capenhurst site originates from the River Dee in Chester or from the domestic water supply. Discharges include cooling water from the operational enrichment plants, effluents arising from neutralising and effluents tanks, and chemistry services effluents. Future Arisings New arisings are expected to be classified as LLW. In view of this, it is anticipated that these arisings will be managed using existing waste service providers, as the character of the waste is not going to be significantly different to existing wastes on site. The management options for the future arisings identified above include on site treatment, disposal of out of scope materials and metals recycling. URENCO UK Limited 13

Capenhurst Nuclear Services Residues The residues held by CNS are from the decommissioning of the former diffusion and centrifuge plants and contain uranyl fluoride (UO 2 F 2 ) and uranium tetrafluoride (UF 4 ). The non-oily residues are sent to the National Nuclear Laboratory (NNL) for processing: NNL is also currently trialling a route for oily residues. Similar to UUK, CNS is largely dependent upon the approval of the 3516B package whilst looking at alternative transport strategies should approval be delayed. Solid Radioactive Wastes The potential disposal routes for the radioactive wastes include recycling, disposal in accordance with environmental permit requirements, incineration and out of scope. Preferred disposal routes for individual waste streams are identified in the CNS BAT optioneering report. Gaseous Radioactive Waste Radioactive gaseous effluent is discharged to the environment from the Bottle Wash Facility and from ventilation systems within the miscellaneous waste preparation and storage area in compliance with the CNS Radioactive Substances Activities (RSA) Environmental Permit. Situated within the miscellaneous waste preparation and storage area are the High Enriched Uranium (HEU) and Low Enriched Uranium (LEU) units, which discharge gaseous effluent into the general building ventilation system via HEPA filtration. This treated gaseous effluent combines with general building ventilation and is discharged to the environment unfiltered via wall louvres. A wet venturi scrubber and packed column provides abatement of gaseous effluent from the Bottle Wash Facility. Aqueous Radioactive Waste Aqueous radioactive waste from the miscellaneous waste preparation and storage area is discharged to the environment in accordance with the CNS RSA Environmental Permit. The Bottle Wash Facility is a closed loop system and produces no aqueous radioactive waste discharges to the environment. Non-Radioactive Liquid Effluent Non-radioactive liquid effluent in the form of trade effluent (treated decommissioning liquors) is discharged to the site surface water drain in accordance with the CNS Environmental Permit. Non-Radioactive Wastes All office wastes, maintenance and general operational wastes are managed by the site facilities management contractor and transferred to a registered waste broker for recycling and recovery. Future Arising The management strategies for the future arisings identified above include disposal of out of scope materials recycling, incineration and land disposal. Significant future waste arisings, from decommissioning activities and the operation of the Legacy Cylinder Facility (LCF) have been estimated for inclusion in the UK Radioactive Waste Inventory (RWI). Management of all future arisings will be in accordance with established procedures, as outlined above. URENCO UK Limited 14

URENCO Chemplants Limited No radioactive wastes will be generated until active commissioning of the plant has commenced. Non-Radioactive Solid Wastes During the construction phase, the TMF project is working to a Site Waste Management Plan (SWMP) in accordance with the SWMP Regulations 2008. The SWMP identifies the waste types that are expected to be generated, estimated quantities and measures that will be used to minimise those wastes. It also provides for a mass balance to identify any anomalies between what is expected to be generated and what is actually generated. Non-radioactive wastes generated from this project are segregated at source and transferred to a registered waste broker for recycling and recovery in alignment with the waste hierarchy. The TMF Construction Site does not currently generate any radioactive liquid or gaseous effluents. Surface Water is managed through a Surface Water Management Plan. Future Arisings Once operational, UCP expects to generate both radioactive and non-radioactive wastes and will require an Environmental Permit for Radioactive Substances Activity and an Installations Environmental Permit. The management of these wastes is described in the Installations (ref 6) and Radioactive Substances (ref 7) Permit applications and these management arrangements will be further enhanced in the period leading up to active commissioning of the facility, currently scheduled to commence in the second half of 2015. It should be noted that the waste hierarchy has been applied at all stages of the design process. As part of the improvement conditions of UCP s Radioactive Substance Activity (RSA) Environmental Permit, BAT assessments will be reviewed by 1st June 2018 or three years from commencement of active commissioning to ensure the original assumptions were correct. 3.2 Setting objectives The Key strategic objectives for integrated waste management at the Capenhurst site are: Wastes are managed in a safe and cost-effective manner and measures to minimise the total quantity of waste generated and its activity are applied during the design, construction, commissioning, operation and decommissioning of a facility through the effective application of the waste hierarchy and through the demonstration of BAT. Measures are implemented to prevent leakage and escape of waste. Avoid generation of orphan wastes i.e. materials having no identified disposal route. Maximise the potential for recycling or reuse of materials. Wastes will be characterised, segregated and, where required, stored in accordance with good practice. Accumulation of wastes on site should be minimised so far as is reasonably practicable. Where wastes are discharged from the site or disposed of off-site, BAT is applied to minimise potential impacts to the public and the environment. Arrangements will be made for monitoring, documenting and reporting on waste programme performance. URENCO recognises the need to manage its historic, current and future waste arisings. To manage these wastes in an expedited and compliant manner, a Legacy Waste Project has been set up by UUK, a primary objective of which is to recharacterise and open up disposal routes to manage this waste and future waste arisings. Coupled with this is a requirement to devise a long-term plan to ensure the quantity of waste produced and stored on site is minimised. Project actions and milestones are included in the IWS Action Plan discussed in Section 6. URENCO UK Limited 15

The Legacy Waste Project will ensure suitable waste routes are available, waste is characterised to the correct specifications and disposed of as soon as practicable. Once established, a target will be to operate with a minimal interim storage period on site before disposal. As part of addressing our IWS objectives and actions, there are activities that need to be undertaken by UUK to support this plan. Verification of the existing waste inventory for each of the companies operating at URENCO Capenhurst, resulting in a revised on-site waste inventory. Development of a robust process to ensure accurate predictions of future arisings based on operational changes. Establishment and maintenance of valid disposal routes for all waste streams. Identification of waste management projects where further investigation or investment is required. Minimisation of all waste through implementation of the waste hierarchy. Creation of consolidated waste management and storage areas. Updating and monitoring of the waste programme across the site to ensure that it remains within strategic tolerance, that the objectives are met and that the associated benefits can be quantified. It is recognised that CNS has taken the lead in developing a waste management programme due to its focus on decommissioning and good practice from this will be adopted. UCP is still in the construction phase, and waste management facilities and arrangements are in the process of being developed in preparation for inactive and active commissioning. 3.3 The Waste Hierarchy The waste hierarchy is a key underpinning element of the IWS and provides an order of preference for waste management options to minimise the volume of waste designated for disposal, as shown in Figure 2. The principles of the waste hierarchy are to focus on actions that involve the generation of primary or secondary wastes. URENCO has made a commitment to avoid waste generation whenever possible. The principles of the waste hierarchy are: Waste generation should be avoided or minimised at source where possible. Waste materials or products should be reused or recycled. The final disposal method, where waste generation cannot be avoided and wastes recycled or reused, is incineration or land disposal. Figure 2: The Waste Hierarchy URENCO UK Limited 16

For LLW requiring disposal, Government policy and national strategy is to minimise waste disposal to the national Low Level Waste Repository (LLWR) wherever possible, firstly by aiming to minimise wastes requiring disposal, and secondly where disposal is the only option to seek alternative disposal routes or treatment options to minimise volume. The waste hierarchy has been fundamental in the development of current operations and its use, demonstrated through application of BAT, will be continued in the construction, operation and ultimate decommissioning of installations on the Capenhurst site. The approach that URENCO uses to comply with this is discussed further in Section 4. URENCO operates a number of initiatives to minimise the quantity of waste consigned as radioactive waste. Examples of such initiatives include: Unpacking materials and supplies outside radiologically designated areas. The Site operates an on-site facility to refurbish Respiratory Protective Equipment, thus avoiding generating additional waste. Selection of materials based on their ability to be decontaminated or reused. Miscellaneous metallic components from the plant are cleaned at the decontamination facility for subsequent reuse, recycling or disposal as appropriate. Promotion of a clean to clean policy whereby surfaces are cleared of spillages and cleaned to a state where no radioactive contamination can be detected. Uranic residues are commercially valuable and are therefore sent off-site for recovery, thus minimising the volume of radioactive waste. Where appropriate, cold traps and chemical absorbers are used to reduce the quantity of UF 6 and HF entering the Gaseous Abatement Systems. Connection and disconnection procedures have been developed that minimise the potential for a UF 6 leak. Segregation at Source, to minimise impacts during operations, sorting and segregating of wastes takes place at designated waste stations located in each plant. Wastes are hand monitored at designated waste sorting stations and sorted based on the monitoring results - either as radioactive or non-radioactive waste. The following general principles are applied across the URENCO business to minimise hazardous waste arisings: When buying chemicals, Material Safety Data Sheets (MSDS) are reviewed and where possible, alternative products are identified to replace those having hazardous or toxic properties. Over-purchasing of chemical substances (including oils) is discouraged. Chemical substances (including oils) are stored in a safe and environmentally responsible manner so as to prevent spillages which would contaminate other materials. Information Technology equipment is recovered through a supplier refurbish and re-use scheme, along with smaller office consumables. When contracts are negotiated with suppliers of material which would ultimately be disposed of as hazardous waste, recycling take-back schemes are explored and implemented e.g. recycling of fluorescent tubes. URENCO UK Limited 17

3.4 Interaction with other strategies and plans This IWS has been developed to be consistent with the following directives and strategies: European Union Directives and international standards and guidance (e.g. from the International Atomic Energy Agency, IAEA). UK policy (e.g. UK policy for the management of LLW (ref 8), national policy for the management of non-radioactive waste (ref 9) and Managing Radioactive Waste Safely (ref 10)). National strategies (e.g. the nuclear industry LLW strategy (ref 11 ), LLW National Programme (ref 12), UK strategy for Radioactive Discharges (ref 13) etc) and regional waste plans (e.g. Cheshire West and Chester Waste Plan) (ref 14). Regulatory requirements set in the respective permits/licences and expectations to demonstrate appropriate radioactive waste management arrangements (e.g. consistency with the Environment Agency Nuclear Sector Plan (NSP)). In addition to the points outlined above, this IWS is also consistent with the URENCO business strategies as discussed below. Decommissioning Strategy The UUK Decommissioning Strategy was developed in 2004 and reviewed by the Health and Safety Executive at the end of that year. The strategy identifies the expected methodology, timescales and costs associated with decommissioning the centrifuge enrichment plant and associated facilities. This document is due to be superseded by a Combined Site Decommissioning Strategy. This document will be developed during 2014 and will cover all operators on the Capenhurst licensed site. It will include the activities of CNS which are currently described in the CNS Annual Plan (ref 15 ). Tails Strategy Tails are a co-product of the enrichment process. The UUK Tails Policy (ref 16) considers Tails to be an asset that can be managed safely on site. The current Tails Strategy describes how Tails, in the form of UF 6 will be transferred to UCP Limited for deconversion to Uranium Oxide which will then be stored on site in a dedicated store for future use. A letter of comfort is being drafted to reassure the regulators that any uranic materials that TMF will generate will not compromise future waste management arrangements. The tails are considered an asset rather than a waste and hence are not directly addressed in this IWS. In the event that legislation, policy and / or economics dictate that tails should be considered as a waste, the IWS will be updated to take account of the management of what would ultimately be a very large volume of ILW. URENCO UK Limited 18

4. Data Gathering The following information provides a summary of the types of waste arising (as discussed in Section 3) and current waste management arrangements that have been identified as BAT. The generation of waste is from the UUK enrichment operations and the management and on-going decommissioning of the former gaseous diffusion plant by CNS. Each company maintains residue and waste inventories that are routinely reviewed and updated. 4.1 What wastes do we generate at present? Wastes currently being generated, those that have been generated in the past and those currently stored onsite are listed in Table 1 columns 2 and 3. This table includes process residues where there is the potential for uranium recovery and which, as such, do not all fall under the formal category of waste. However, as they are a nuclear material being managed on-site, they are included here for completeness. 4.2 What wastes will we generate in the strategy period? Section 3.1 provided a summary of the waste arisings that are expected to be generated in the future. Most of the wastes identified in the table above will continue to be generated, with the exception of Magnesium Fluoride (MgF 2 ) filter material where there are no firm plans to use reprocessed uranium as a feed material. Refer to Table 1 column 4 for details of future arisings. Solid radioactive waste arisings expected to be generated from URENCO at Capenhurst in the future are also detailed in the 2010 UK Radioactive Waste Inventory (ref 17). A revised UK Radioactive Waste Inventory has been drafted during 2013 but is not yet published. URENCO UK Limited 19

5 Critical Evaluation of Waste Management Options The following provides a summary of how wastes are currently managed and what will be needed in the future to manage wastes arising from activities at the Capenhurst Site. It also provides a means for evaluating what waste management, recycling and disposal routes may be required in the future. 5.1 What do we do at present? As described earlier in Section 2.3, URENCO demonstrates the application of BAT by consideration of a range of optimisation factors and waste minimisation techniques. This IWS takes account of the conclusions drawn from the 2011 BAT assessment as referenced earlier. Solid and non- aqueous waste Wastes are segregated at source. Metallic wastes are decontaminated. Waste is monitored to determine if it is radioactive. o Wastes are sampled and in addition low density wastes are scanned using a drum scanner. Finally wastes are then batched for consignment to LLWR segregated waste services. Gaseous waste Process vents and active area room ventilation systems are filtered using HEPA filtration. o In addition, process vents are filtered using chemical ad/absorbers. o Where process vents have high moisture content wet venturi scrubbers substitute for HEPA filtration. Discharges are continuously sampled by taking a proportion of the discharge and passing it through a filter paper (for low moisture content discharges) or a bubbler rig. Discharges are monitored for effluent flow. Aqueous liquids waste Liquid effluents are collected in effluent tanks. A representative sample is taken for analysis before discharge is approved. Discharges are monitored for effluent flow and total volume. Waste Management Resources In compliance with the requirements of its RSA Environmental Permits, URENCO has both a Corporate Radioactive Waste Advisor (CRWA) and a resource of Suitably Qualified and Experienced Persons (SQEP) to advise on the following areas: Compliance with Environmental Permits and demonstration of BAT. Accounting and recording of waste disposals. Supervision of waste disposal activities. Radiological dose assessment. Calibration of radioactive discharge sampling and monitoring instrumentation. Chemical analysis of waste and environmental samples. Design and engineering of radioactive liquid and gaseous discharge systems. Site drainage infrastructure. Maintenance and testing. URENCO UK Limited 20

Arrangements made for compliance with Environmental Permits and Nuclear Site Licence requirements are implemented through Company Instructions. These place responsibilities on specified individuals within the organisation and require that radioactive and non-radioactive wastes, whether in gaseous, liquid or solid form, are minimised, collected, segregated, stored if appropriate, and disposed of effectively in accordance with the disposal permits, legislation and industry good practice. 5.2 What will be needed in the future? As operations on the Capenhurst site are being expanded and diversified, waste arisings and their management needs will change over time (see future waste arisings in Table 1). These changes will be a result of the requirement to decommission existing plants, changes to existing processes and potential new processes being adopted by URENCO. A key requirement is the need to ensure that existing waste stocks on site are minimised through the continual availability of waste disposal routes. This is discussed further below. Key strategic investment decisions relate to the provision of: Site capability for waste processing and packaging. Currently wastes are stored in multiple areas across the site. Going forward, a centralised waste management area may be advantageous to process and consolidate wastes prior to offsite disposal. Third party final disposal, recycling or processing facilities. As waste arisings are expected to change in the future, various external groups e.g.llwr are being consulted at the planning stage to identify potential new disposal routes. Uranic residue processing capability. It is recognised that there is reliance upon the facilities at Springfields Fuels Limited for residue processing which are understood to have a limited lifetime. URENCO is in the early stages of considering mitigation for this risk. Radioactive material transport capability. URENCO is actively managing the work of the transport package supply chain to ensure timely approval and availability of transport packages for wastes and residues. It is also anticipated that future changes to the transport regulations may have an impact on movement of waste and residues. URENCO is actively engaged in industry discussions in anticipation of the regulatory change and is currently assessing the potential effects on operations. 5.3 Are existing routes and plans satisfactory? Recently, UUK performed a gap analysis of the current waste management programme and arrangements to determine if the existing programme was satisfactory and met both regulatory and permit/licence conditions. The gap analysis identified several areas for improvement to support both onsite waste management activities and offsite disposals. An action plan to address these findings has been developed and will be submitted to the Site s senior management for approval. Once the Gap Analysis Action Plan has been approved, modifications or additions may be incorporated into the IWS Action Plan. Since the commencement of CNS operations in 2012, CNS has been through a transition period during which operations were limited. There is a robust programme for reopening disposal routes, against which significant progress has been made. URENCO UK Limited 21

6 Horizon The following provides an overview of the key deliverables, threats and opportunities of the waste management programme. 6.1 Key deliverables, decisions and required timescales for delivery Key deliverables and required timescales have been included in the IWS action plan. This sets out the objectives that need to be met, associated actions, who has accountability for the process and the target date for completion. 6.2 Threats (risks) and opportunity management in strategy delivery Threats, or risks, are identified as those things that could have a negative impact to the waste management strategy and associated plan. It acknowledges that there are uncertainties associated with the implementation of the IWS and that contingency needs to be built into the programme and schedule. Table 3 is a summary of potential threats or risk that could exist and the mitigation activities that should be implemented to manage these risks. Table 3 Threats and Mitigation Activities Threat Unavailable disposal routes LLWR disposal route for VLLW is not available Inability to process residues hence adding to the waste inventory Inability to transfer residues Changes in Legislation Mitigation Activities There is a threat that a disposal route for some of the wastes generated onsite may not be available. URENCO is working with waste service providers to open disposal routes for radioactive wastes. At this time, there are no identified issues that will preclude legacy and newly generated wastes being sent offsite for disposal. There are several disposal routes available for the non-radioactive waste such that if one should become unavailable, finding a replacement site should not be an issue. Under current insurance indemnification requirements, VLLW must be disposed via the LLWR contractual framework. If this route becomes unavailable there is a threat that the site would be unable to dispose of VLLW via any other means. There is a risk that recycling capabilities for some of the residues will not always be available (e.g. Springfields Fuels Ltd). In those instances, alterative opportunities will need to be identified, and if no alternative can be identified, the residues will be managed as waste. There is a risk that a licence (or supplier) for a package for the transport of fissile residues cannot be obtained. As mitigation URENCO will consider options for onsite recovery and an alternative transport strategy. There is a risk that changes in legislation could lead to the suspension or unavailability of disposal routes that are currently in use or planned. As mitigation, URENCO is using LLWR segregated waste services to provide multiple waste routes. URENCO UK Limited 22

Opportunities are areas where activities, processes or projects are not currently planned, but where the potential to improve delivery may exist. These typically require ongoing work to assess the benefits, and if deemed feasible, to implement them. Opportunities may include an alternative disposal route which has a positive financial impact, whilst also protecting human health and the environment. Table 4 is a summary of identified opportunities that could impact waste management strategies and activities on the URENCO Site. Table 4 Opportunities and Mitigation Activities Opportunity Prospective Benefit Activities required to Realise Open up a metals recycling route for both radioactive and non radioactive wastes Campaign implementation of supercompaction of compactable waste The operators on the Capenhurst site could optimise waste management and disposals to ensure efficient and cost effective methods by having common disposal routes and single contracts. Engagement with supply chains in a more proactive manner Minimises the disposal of metals and potentially offers financial benefits by managing metallic waste via one route Significant reduction in the volume of compactable waste sent for disposal The URENCO Companies at Capenhurst can work together to optimise waste management on site. Establish a single and consolidated waste management system. To identify most appropriate waste treatment and disposals to landfill, ensure good service and application of the waste hierarchy. Cost benefit and sustainability analysis to determine whether the lifecycle waste management impacts are sufficiently reduced Cost benefit and sustainability analysis to determine whether the lifecycle waste management impacts are sufficiently reduced Cost benefit and sustainability analysis to determine whether waste disposal management impacts are sufficiently reduced Early and regular communication with waste service providers e.g. attending seminars, to establish good relationships and determine industry good practise. 6.3 Action planning An IWS Action Plan has been developed based on: Information included in this document. The identified threats and opportunities. Information obtained from a recent internal gap analysis of the UUK waste management programme. Input from tenants (ETUK, CNS and UCP). Findings from internal assessments and audits. The action plan identifies the objective, actions that need to be taken and a responsible person and target date. Each action has also been ranked according to its priority high, medium or low. Many of the high priority actions, such as the implementation of a new waste management inventory and tracking system, will be complete by the end of quarter 1, 2014, with the remainder complete by the end of quarter 2, 2014. Medium priority actions will follow by the end of 2014 and lower priority actions will continue into 2015. URENCO UK Limited 23

7 Monitoring and Evaluation The following section outlines the timescales for reviewing the IWS and Action Plan, and highlights some of the waste management metrics and indicators that will be used to monitor progress made and the effects of the IWS to assess whether the aims and objectives (benefits) have been realised. 7.1 IWS Review Cycle A full review will be carried out at least once every three years unless triggered by a change in circumstances. Triggers may include: Changes in legislation, regulation or national policies. Changes in URENCO strategic planning for operations on the Capenhurst site. Changes in the availability of waste management routes (whether positive or negative). Changes either in the quantity or types of wastes produced on-site. Change to a management system that would impact the IWS. New scientific or technical waste treatment technologies that become available. Loss or change in a disposal route or change in Waste Acceptance Criteria. And, Lessons learned and monitoring of performance that shows that anticipated benefits are not being achieved. The Action Plan, which is a supporting document of this IWS, will be reviewed and updated at least on an annual basis. The review of the Action Plan could be another trigger for a full review of the IWS. 7.2 Indicators and metrics Appropriate monitoring of indicators and metrics is critical in ensuring that the strategic objectives (the benefits) of the IWS are being realised, or if not, that appropriate changes to waste management arrangements (or strategy) are put in place. This process has three aspects, firstly metrics that are monitored; secondly the assurance process in place to review these, and thirdly, how assurance and associated learning is fed back into the strategy and any required improvements made. Metrics may be both leading (predictive) and lagging (retrospective). Metrics need to be aligned to the strategy for waste management and drive positive waste management behaviours. Metrics to be monitored to evaluate IWS performance are given in Table 5. These metrics will be monitored on a quarterly basis via meetings attended by representatives from all areas of the Capenhurst site. URENCO UK Limited 24

Table 5 Metrics to be Monitored Metric Associated Strategy Benefit Review/Reporting Frequency Quantities of anticipated total future waste arisings Minimisation of waste arisings and strategic planning for waste processing disposal options Annual reviews. Quantity of radioactive waste held on site Minimisation of waste awaiting disposal Quarterly reviews Quantities of radioactive waste diverted from landfill Compliance with the waste hierarchy and minimisation of disposal to landfill Quarterly reviews Quantities of non-radioactive waste diverted from landfill Arisings and management of non-radioactive waste Compliance with the waste hierarchy, amount of waste recycled or and minimisation prior to disposal Compliance with the waste hierarchy Quarterly reviews Quarterly reviews Radioactive discharges to the environment and public dose exposure Demonstration that the dose from discharges to the environment and exposure of the public is ALARA Quarterly reviews 7.3 Reporting and Audit This IWS provides a clear roadmap of how URENCO has set waste management priorities and how we aim to achieve targets. UUK as licensee will be responsible for assurance activities and overall monitoring, collation and reporting of the metrics identified above. A quarterly site meeting will be held to review the above metrics and share lessons learned to ensure continuous improvement of the waste management programme. Quarterly review meetings will be initially scheduled for representatives of all tenants and UUK as licensee to discuss progress, share learning and provide support. This will also be an opportunity to discuss relationships with waste service providers. Each permit holder is required to carry out inspection and auditing, in addition, UUK, as licensee, will carry out internal and independent assurance assessments of waste management activities of the tenants. This will include reviews of management systems and tools, and waste management practices. A summary of any issues or concerns identified will be provided and actions agreed. URENCO UK Limited 25

8 Acronynms BAT Best Available Technique BPEO Best Practicable Environmental Option CNS Capenhurst Nuclear Services Limited CRWA Corporate Radioactive Waste Adviser DECW Demolition, Excavation & Construction Waste EA Environment Agency EPR10 Environmental Permitting Regulations 2010 EP-RSA Environmental Permit for Radioactive Substances Activity ETC Enrichment Technology Company ET UK Enrichment Technology United Kingdom GBq Gigabecquerel GEVS Gaseous Effluent Vent System HEU High Enrichment Uranium HEPA High Efficiency Particulate Air HF Hydrogen Fluoride HSE Health & Safety Executive IAEA International Atomic Energy Agency ILW Intermediate Level Waste IWS Integrated Waste Strategy LA-LLW Low Activity Low Level Waste LCF Legacy Cylinder Facility LLW Low Level Waste LLWR Low Level Waste Repository MBq MegaBecquerel MSDS Material Safety Data Sheet NaDU Sodium Diuranate NDA Nuclear Decommissioning Authority NICoP Nuclear Industry Code of Practice NNL National Nuclear Laboratory NSP Nuclear Sector Plan ONR Office for Nuclear Regulation PFPE Perfluoropolyether SQEP Suitably Qualified and Experienced Person SWMP Site Waste Management Plan TMF Tails Management Facility TVT Terminal Valve Test U 3 O 8 Triuranium Octoxide UCP URENCO ChemPlants Limited UEC URENCO Enrichment Company UF 6 Uranium Hexafluoride UUK URENCO UK Limited VLLW Very Low Level Waste VPDF Vacuum Pump Disassembly Facility WEEE Waste Electrical and Electronic Equipment URENCO UK Limited 26

9 References 1. Environment Agencies Guidance On Roles and Responsibilities of Permit Holders and Radioactive Waste Advisers Document Ref: RWA-G-1 Version 1.0 Publication date: 24 May 2011 2. Specification and Guidance on the Content and Format of an Integrated Waste Strategy (Doc No ENG 01, October 2012) 3. Best Available Techniques (BAT) for the Management of the Generation and Disposal of Radioactive Wastes A Nuclear Industry Code of Practice. December 2010. 4. Best Available Techniques (BAT) Case: UUK Radioactive Process Materials and Waste, ENE/0034/AP/FR1, December 2011. 5. Permit with introductory note. Pollution Prevention and Control (England & Wales) Regulations 2000. Permit number WP 3939 SC (Variation notice CP3831UP). 6. Application for an Environmental Permit Under Regulation 13 of the Environmental Permitting (England and Wales) Regulations 2010 to Enable URENCO ChemPlants Limited to Operate a Tails Management Facility, TOEA/2010/03 March 2010 and TOEA/2012/04 August 2012. 7. UUK6025088 Information in Support of Application to Partially Transfer Limits and Conditions from the URENCO UK Limited Radioactive Substances Act 1993 Authorisation (CA8205/CD9224) to URENCO ChemPlants Limited Under Section 16A of the Radioactive Substances Act 1993. Revision 1, 22nd December 2009. 8. UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry. Published August 2010 9. Waste Strategy for England 2007. 10. Managing radioactive waste safely: a framework for implementing geological disposal. Published June 2008 11. Nuclear industrial strategy: the UK s nuclear future. Published March 2013 12. National Waste Programme. Programme Manual Implementation of the National Low Level Waste Programme. Issued March 2012 13. UK Strategy for Radioactive Discharges. Published July 2009 14. Cheshire Replacement Waste Local Plan. Published July 2007 15. NDA Annual Plan 2013-2014 4th January 2013 (12.37-CNS-0008) 16. Uranium Hexafluoride Tails Policy. Issued June 2012 17. The 2010 UK Radioactive Waste Inventory. February 2011. URENCO UK Limited 27