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Best Practicable Environmental Option Review for Devonport Royal Dockyard

COMMERCIAL IN CONFIDENCE


FNC 39078/37483R Issue 1

Prepared for Babcock International Group

SYSTEMS AND ENGINEERING TECHNOLOGY

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DOCUMENT INFORMATION

Project :

Report Title : Best Practicable Environmental Option Review for Devonport Royal Dockyard

Client : Babcock International Group

Client Ref. : 228382-02

Classification : COMMERCIAL IN CONFIDENCE

Report No. : FNC 39078/37483R

Issue No. : 1 Compiled By :

Date : 13 May 2011

Paul R Jarvis

Approved By : Tony P McConnell

DISTRIBUTION

Copy Recipient Organisation

1 Alan Harper Babcock

2 Sharron Wormald Babcock

3 Harvey Grant Babcock

4 Brent Wright Babcock

5 File Frazer Nash Consultancy

Copy No.: ______

COPYRIGHT

The Copyright in this work is vested in Frazer-Nash Consultancy Limited. The document is issued in confidence solely for the purpose for which it is supplied. Reproduction in whole or in part or use for tendering or manufacturing purposes is prohibited except under an agreement with or with the written consent of Frazer-Nash Consultancy Limited and then only on the condition that this notice is included in any such reproduction.

Originating Office: FRAZER-NASH CONSULTANCY LIMITED 1st Floor, Gordon Court, 4 Craigie Drive, The Millfields, Plymouth, PL1 3JB, UK

T: +44 (0)1752 675760 F: +44 (0)1752 603941 W: www.fnc.co.uk

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SUMMARY

This report provides a comprehensive review of Devonport Royal Dockyard Limited’s (DRDL’s) current radioactive waste disposal / discharge routes to assess whether they represent the Best Practicable Environmental Option (BPEO) for waste disposal from the site.

This review comprises the following stages:

� Confirmation of existing waste routes;

� Review of existing BPEO reports to ensure they cover the waste routes and to ensure that they still represent BPEO;

� Review against the Best Available Techniques (BAT) Code of Practice;

� Inspection of Environment Agency Requirements Working Group (EARWG) database;

� Check impact of the BPEO review on the Integrated Waste Strategy (IWS).

A description of waste arisings at Devonport Royal Dockyard (DRD) together with authorised discharge routes and applicable BPEO studies is shown in Table 1. This review confirms that, with the exception of the gaseous discharge route, BPEO studies exist for all of DRDL’s waste streams. Given that discharge of gaseous waste to the environment is a straightforward route, with few options, it is considered that a BPEO is not required for this discharge route.

The BPEO studies provided by Babcock follow the key principles of the Environment Agency’s (EA) guidance [Reference 1]. The process for identifying options, screening, performance criteria, scoring and weighting is carried out in accordance with the EA guidance. Relevant stakeholders have been involved in the BPEO studies although in some instances a listing of stakeholders is not provided in the BPEO study reports. For future reviews there should be a stakeholder register including a statement of qualification demonstrating that they cover the appropriate disciplines and are Suitably Qualified and Experienced Personnel (SQEP). For future studies consideration should be given to defining a set of essential criteria and then screening out options that do not meet these criteria. This would save time and resource for future studies.

It is noted that the BPEO studies do not explicitly cover “social, economic and security” impact. This is one of the “top tier” of factors that the EA expect to see considered as part of a BPEO study. Babcock should review the impact of this factor on their BPEO studies. This factor could impact on the outcome of the BPEO studies particularly in studies where the options vary from treatment and direct disposal from site, through to transportation, treatment and disposal off-site.

It is noted that the BPEO reviews do not consider uncertainties, and some do not specify gaps in knowledge. However, this doesn’t undermine the value of the BPEO studies. Each of the BPEO studies provides a set of assumptions and these are generally based on referenced data from site (e.g. radionuclide concentrations, volumes and radiological assessments). Assumptions have also been made on the continued availability of facilities (for example, encapsulation and compaction at Winfrith). There will be some uncertainty associated with this, but if a particular disposal route does become unavailable then the BPEO study would be revisited to determine the next best option. For future reviews, any significant uncertainty associated with each option and their performance criteria should be identified. If the option study panel cannot identify any significant uncertainties in the supporting information, then a statement confirming this should be included within the study report.

The sensitivity studies carried out for each BPEO review are extensive and cover the effect of variations in scoring and weighting from different stakeholder perspectives. It is noted that the results of the sensitivity studies do not change the outcome of the BPEO reviews.

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It is noted that the BPEO reports use different weighting factors. For example, the weighting factor for environmental impact varies from 1.78 (low) for the boronated liquid BPEO study, to 8 (high) for the sewer discharge BPEO study. However, the sensitivity analyses confirm that the identification of the most favoured option in the base case assessments is not affected by substantial variation in the weighting ratios.

In general, the BPEO studies meet the requirements of the BAT process. The one area where BAT process does not appear to have been followed is in the identification of uncertainties and knowledge gaps. As Babcock move towards adopting the BAT process, this should be considered in future reviews. Given that BAT has now replaced BPEO, Babcock need to develop a BAT methodology and ensure that the IWS is updated to reflect the change in policy and to reference out to BAT studies as they are produced.

Proportionality has been adopted in the BPEO studies, and the level of effort expended to resolve an issue, and record the selection process, is seen to be appropriate to the range of options available as is the extent to which precedent and established good practice can be used to assist the decision making process.

Therefore, this review of the BPEO studies endorses that the options provided by Devonport for disposal of waste remain the BPEO for the site.

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ABBREVIATIONS

Abbreviation Description

ALARP As Low As Reasonably Practicable

AWTP Active Water Treatment Plant

BAT Best Available Techniques

BPEO Best Practicable Environmental Option

BSO Basic Safety Objective

DRD Devonport Royal Dockyard

DRDL Devonport Royal Dockyard Limited

EA Environment Agency

EARWG Environment Agency Requirements Working Group

ERSS Environmental Radiation Safety Section

ETP Effluent Treatment Plant

HPO Health Physics Operations

ILW Intermediate Level Waste

ISO International Standards Organisation

IWS Integrated Waste Strategy

LLW Low Level Waste

LLWR Low Level Waste Repository

MRF Metal Recycling Facility

NDA Nuclear Decommissioning Authority

NEMSFAC New Equipment Maintenance and Storage Facility

NII Nuclear Installations Inspectorate

NSF Nuclear Support Facility

NUB Nuclear Utilities Building

OSPAR Oslo Paris Convention (Framework for preventing and eliminating pollution in the north-east Atlantic)

PWR Pressurised Water Reactor

R&D Research & Development

RSMDP Radioactive Substance Management Developed Principle

SCPM Safety Case Project Manager

SQEP Suitably Qualified and Experienced Person

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Abbreviation Description

SRC Submarine Re-Fit Complex

SSN Ship Submersible Nuclear

TFS Trans Frontier Shipment

TSSBN Trident Ship Submersible Ballistic Nuclear

VLLW Very Low Level Waste

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DEFINITIONS Best Available Techniques (BAT)

BAT is defined according to the Pollution Prevention and Control Directive as “the most effective and advanced stage in the development of activities and their methods of operation which indicates the practical suitability of particular techniques for providing in principle the basis for emission limit values designed to prevent and, where that is not practicable, generally to reduce emissions and the impact on the environment as a whole” [Reference 2].

According to the Oslo Paris Convention (OSPAR), BAT “means the latest stage of development (state of the art) of processes, of facilities or of methods of operation which indicate the practical suitability of a particular measure for limiting discharges, emissions and waste” [Reference 3].

BAT is the latest set of techniques which are designed to allow for the operations of particular activities to be performed whilst meeting certain standards which attempt to minimise, if not totally eradicate any potential environmental damage. BAT is an attempt at trying to bring together the standards for meeting Best Practicable Means and BPEO into a single document which permits for transparency in the expected areas of performance.

BAT works with the most up-to-date methods and practices and encourages these from the variety of activities being undertaken whereby there is the potential for any environmental impact.

Operators should use BAT to achieve a high degree of protection of the environment, taken as a whole and to meet the principle of optimisation and in so doing they will have reduced discharges and exposures to as low as reasonably practicable (ALARP). This, together with consideration of the local environmental conditions, the technical characteristics of the facility and its location provides the basis for permit condition and limit values. The BAT approach involves consideration of costs and benefits to ensure that the cost of applying techniques is not grossly disproportionate in relation to the environmental protection they provide.

Best Practicable Environmental Option (BPEO)

BPEO has been defined by the Royal Commission on Environmental Pollution as "the outcome of a systematic consultative and decision making procedure which emphasizes the protection and conservation of the environment across land, air and water” [Reference 4]. The BPEO procedure establishes for a given set of objectives, the option that provides the most benefits or the least damage to the environment, as a whole, at acceptable cost, in the long term as well as in the short term.

Best Practicable Means (BPM)

BPM is a wide-ranging principle that reflects the duty imposed by the Environment Agency to ensure that radioactive wastes are:

• Not created unnecessarily;

• Safely and appropriately managed (including interim and / or, if necessary, long-term storage), processed and, where applicable, treated;

• Disposed / discharged of at appropriate times and in appropriate ways to minimise radiation dose to members of the public from their management and disposal.

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CONTENTS

1. INTRODUCTION 9

2. EXISTING WASTE STREAMS 10

2.1 LIQUID RADIOACTIVE WASTE 10

2.2 SOLID RADIOACTIVE WASTE 11

2.3 GASEOUS WASTE 13

2.4 SUMMARY 13

3. REVIEW OF BPEO REPORTS 17

3.1 BPEO PROCESS 17

3.2 STAKEHOLDER PARTICIPATION 17

3.3 OPTIONS 18

3.4 SCREENING 19

3.5 SELECTION OF PERFORMANCE CRITERIA 19

3.6 SCORING 19

3.7 WEIGHTING FACTORS 21

3.8 SENSITIVITY ANALYSIS 22

3.9 UNCERTAINTY 22

4. REVIEW AGAINST BAT 24

5. REVIEW OF EARWG DATABASE 26

6. IMPACT OF BPEO REVIEW 27

7. RECOMMENDATIONS 28

8. CONCLUSIONS 29

9. REFERENCES 31

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1. INTRODUCTION

DRDL have completed a number of BPEO studies for a wide range of radioactive waste streams. These studies are:

� BPEO Study on Management Options for Solid Low Level and Very Low Level Waste [Reference 5];

� BPEO Study on Options for Reducing Discharges to Sewer [Reference 6];

� BPEO Study on the management Options for Filter and Wet Sludge Waste Streams [Reference 7];

� BPEO Study on Management Options for Boronated Liquid Wastes [Reference 8];

� BPEO Study on Management options for Spent Ion Exchange Resin [Reference 9];

� Spent Radioactive Ion Exchange Resin Arising from Ship Submersible Nuclear (SSN) and Trident Ship Submersible Ballistic Nuclear (TSSBN) Reactor Plant [Reference 10].

A BPEO study was also conducted as part of the recent application to vary the authorisation for disposal of radioactive waste [Reference 11]. This study covered options for:

� Organic liquid waste;

� Fission chambers;

� Intermediate Level Waste (ILW) items;

� Surface Contaminated Metallic Waste.

A feasibility study has also been conducted for a pipeline to discharge treated radioactive effluent [Reference 12]. This feasibility study included a BPEO study to cover discharges into the Hamoaze.

This report provides a comprehensive review of DRDL’s current radioactive waste disposal / discharge routes to assess whether they represent the BPEO for waste disposal from the site.

This review comprises the following stages:

� Confirmation of existing waste routes;

� Review of existing BPEO reports to ensure they cover the waste routes and to ensure that they still represent BPEO;

� Review against the BAT Code of Practice;

� Inspection of EARWG database; and

� Check impact of the BPEO review on the IWS.

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2. EXISTING WASTE STREAMS

The first stage of this review was to identify all existing waste streams at Devonport. This would then enable a decision to be made as to whether BPEO reports exist for all waste streams.

DRDL’s existing liquid and solid waste streams are illustrated in Figure 2 and Figure 3 respectively.

2.1 LIQUID RADIOACTIVE WASTE

Liquid radioactive waste generated at Devonport comprises aqueous and organic liquid waste. Following appropriate sentencing and effluent treatment (if appropriate), aqueous liquid waste is generally discharged to the Hamoaze and the sewer. Organic liquid waste comprises small amounts of oily waste and contaminated chemicals. Organic liquid wastes are disposed of by incineration off-site.

2.1.1 Primary Aqueous Waste

The generation of primary aqueous waste is a direct consequence of the refit, defuel, refuel, repair and maintenance of nuclear powered submarines at DRD, particularly operations carried out on the Pressurised Water Reactor (PWR) primary circuit and associated cooling system. These liquid wastes are treated using strainers, filters and mixed bed ion exchange columns within the Active Water Treatment Plant (AWTP) and / or Effluent Treatment Plant (ETP) prior to discharge into the Hamoaze via a single dedicated pipeline.

Boronated liquid waste is also generated at Devonport. Boron may be added to the primary circuit in order to maintain a high level of criticality safety during defuel/refuel and pre-defuel lay-up. When the boat has been de-fuelled, the boronated effluent needs to be removed and disposed of. An existing disposal route exists via an incinerator plant at Hythe. Small concentrations of boron may be disposed of to the Hamoaze.

2.1.2 Secondary Aqueous Waste

Secondary aqueous wastes are non-process arisings that are produced as a result of activities that support nuclear and radiological operations at the dockyard. These liquids arise from:

� Nuclear Utilities Building (NUB) laundry;

� Reactorchemistry laboratory;

� Showers and hand basins within change rooms;

� Floor drains within radiologically controlled areas;

� Wash and flush arisings.

The discharge routes for secondary liquid wastes are:

� To the dockyard sewer system;

� To the ETP with subsequent discharge to the Hamoaze.

2.1.3 Organic Liquid Waste

Small volumes of contaminated oily waste can also arise during the refit and repair of nuclear powered submarines at DRD. It is anticipated that a small volume of oily waste will arise each year.

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Small volumes of contaminated chemicals (e.g. solvents) are generated during routine operations within the reactorchemistry laboratory and will continue to be generated each year as a result of continued analyses.

An existing disposal route exists for organic liquid waste via an off-site incinerator at Hythe.

2.2 SOLID RADIOACTIVE WASTE

Solid radioactive waste generated at DRD falls into four distinct categories:

� Very Low Level Waste (VLLW);

� Wet Low Level Waste (LLW);

� Dry LLW; and

� ILW.

2.2.1 VLLW

VLLW comprises protective clothing, rags, paper, filters, polythene shielding, broken pipework and other miscellaneous metal. Non-resin VLLW is disposed of to a licensed landfill site.

2.2.2 Wet LLW

Wet LLW comprises filters, sludges, ion exchange resin, wet protective clothing, rags, wet wipes, paper towels, polythene etc.

Filters are used within the effluent treatment systems to remove radioactive particulates from effluent.

Sludges can accumulate over time within effluent tanks. These can lead to localised radiation hot spots around the tanks. These sludges are removed during the clean up of effluent tanks.

The current approach for disposal of non-resin wet LLW wastes is drying followed by supercompaction. Supercompaction reduces the overall volume of waste by a factor of ~4. This is currently undertaken at Winfrith, and the BPEO study [Reference 7] assumes that the process would continue to be used in the future.

Ion exchange resins are used to remove soluble radioactive materials during the clean up of liquid effluents. When the capacity of these resins is exhausted, the resins become wet solid waste. The sources of resin waste are:

� Submarine primary circuit coolant clean-up system;

� Alternative Core Removal Cooling System;

� Submarine primary circuit chemical decontamination plant;

� ETP;

� AWTP;

� Low Level Refuelling Facility.

Ion exchange resin is stored in a purpose built on-site resin storage facility prior to transfer and disposal off-site. Resins meeting the LLWR Waste Acceptance Criteria are transferred to Winfrith for pre-treatment, encapsulation and final disposal to the Low Level Waste Repository (LLWR) at Drigg. Resins with significant levels of contaminants (C-14 and / or chelating agents) that could hinder waste processing / disposal are currently stored on site awaiting decay and / or development of a treatment process or disposal route.

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2.2.3 Dry LLW

The “dry” solid waste that arises during normal operations at DRD is derived from materials that have been used within radiologically controlled areas. This includes clothing, paper, polythene, tools, lagging and pipework. All such material is treated as if it was radioactive and is managed accordingly.

Dry LLW is processed (e.g. supercompacted) prior to being packaged in International Standards Organisation (ISO) freight containers and sent to the LLWR at Drigg. Consignment to LLWR no longer automatically implies grouting and vault disposal. It is noted that LLWR Limited now offer a range of services to manage low level radioactive wastes including:

• Metallic waste (e.g. recycling, shot blasting, size reduction, melting);

• Combustible waste (thermal treatment to reduce volume);

• Supercompactable waste (compaction of loose waste and drums).

LLWR Limited have produced strategic BPEO studies covering High Volume LLW, metallic waste and combustible waste.

Options also exist for despatching contaminated metals to the Metal Recycling Facility (MRF) in Lilyhall, or to Studsvik’s melting plant in Sweden via Trans Frontier Shipment (TFS). Melting of contaminated metals effectively separates the radioactive component from the waste and hence reduces the quantity of radioactive waste that ultimately needs to be disposed of.

A strategic BPEO study for contaminated metallic waste management, undertaken on behalf of the Nuclear Decommissioning Authority (NDA) [Reference 13], identified waste treatment in an overseas facility as the best option.

In August 2007, DRDL carried out an in-house option study [Reference 14] which broadly reached the same conclusion as the NDA strategic BPEO study. At that time, the UK MRF was not far enough forward to be considered in detail; however the DRDL study concluded that mechanical decontamination followed by recycling at a national facility would be the second best option after melting. It is recommended that the BPEO study for management of core pond furniture is revisited and modified to allow for all contaminated metals [Recommendation 1].

Given that the UK MRF is now available, DRDL have transferred contaminated metallic waste to that facility for decontamination by blasting. A significant amount of waste is now sent to the MRF.

2.2.4 ILW

Components from the primary circuit and reactor plant may need to be replaced during maintenance and repair at DRD. On occasion, these components may be ILW (e.g. thermocouple probes).

ILW is stored on DRDL’s Nuclear Licensed Site until it decays to LLW or is transferred to Windscale for storage pending the availability of an onward management option such as an ILW repository.

2.2.5 Nucleonic Detectors containing fission chambe rs

Nucleonics detectors, removed from submarines, contain fission chambers. The detectors are dismantled to separate the detector and fission chamber. The assembly is sent to Winfrith for compaction to minimise the volume prior to disposal at the LLWR at Drigg. It is noted that this route is under review due to new limitations on fissile material at the Winfrith site.

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2.3 GASEOUS WASTE

DRDL are also authorised to discharge low levels of radioactive gaseous waste to the environment. The Authorisation Variation [Reference 15] gives details of the discharge outlets. It is noted that the BPEO studies provided for review [References 5, 6, 16, 7, 8, 9 and 10] do not include gaseous waste.

Given that discharge of gaseous waste to the environment is a straightforward route, with the only option being to filter or not filter the extracts and discharge outlets, it is considered that a BPEO is not required for this discharge route.

2.4 SUMMARY

A description of waste arisings at DRD together with authorised discharge routes and applicable BPEO studies is shown in Table 1.

This review confirms that, with the exception of the gaseous discharge route, BPEO studies exist for all of DRDL’s waste streams. It is considered that a BPEO study for discharge of gaseous waste to the environment is not required.

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Table 1 - Waste Arisings, Disposal Routes and Appli cable BPEO Studies Description of Waste Arisings Disposal Route BPEO S tudy

ILW

Spent ion exchange resins, submarine reactor components and plant items.

Storage on site until decayed to LLW.

Transfer of some items (e.g. thermocouple probes) to Windscale.

SO

LID

VLL

W /

LLW

/ IL

W

Wet LLW

Spent resins, filters, sludges, wet paper etc.

Dry LLW

Cartridge filters, filters, clothing, paper, polythene, tools, lagging, pipework.

Compactable (soft) and non-compactable (hard) waste is packed into 200 L drums and then into a half height ISO container or directly into the container and then taken to LLWR at Drigg for final disposal or initially via Winfrith for super-compaction.

Non-compactable waste too large to be cut up or dismantled require special arrangements, but those items which can, are put into the ½ height ISO container and transferred to LLWR at Drigg for emplacement in vault 8.

Resins meeting the LLWR Waste Acceptance Criteria are transferred to Winfrith for pre-treatment, encapsulation and final disposal to the LLWR at Drigg. Resins with significant levels of contaminants (e.g. C-14 and / or chelating agents) that could hinder waste processing / disposal are currently stored on site awaiting decay and / or development of a treatment process.

BPEO Study on Management Options for Spent Ion Exchange Resin [Reference 9].

Spent Radioactive Ion Exchange Resin Arising from SSN and TSSBN Reactor Plant Decontamination and On Board Primary Coolant Treatment at Devonport Royal Dockyard- Phase 2 Report – Option on Strategy Selection [Reference 10].

BPEO Study on the management Options for Filter and Wet Sludge Waste Streams [Reference 7].

BPEO Study on Management Options for Solid Low Level and Very Low Level Waste [Reference 5].

Application for a Variation to DRDL’s Authorisation for Disposal of Radioactive Waste from Devonport Royal Dockyard [Reference 11].

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Description of Waste Arisings Disposal Route BPEO S tudy

VLLW

Protective clothing, rags, paper, filters, polythene shielding, broken pipework, miscellaneous metal.

VLLW is disposed of to a specified licensed landfill site.

SE

CO

ND

AR

Y A

QU

EO

US

W

AS

TE

Discharge of liquid to the dockyard sewers include:

Clean and dirty waste water including showers and change room water

Waste water from sinks and personal decontamination showers

Liquid arisings from general sample analysis

Water discharged from the NUB laundry room NUB Changing Room.

System provided by the operator for discharging sewage and storm water to a large scale Sewage Treatment Works.

Arisings from the reactorchemistry laboratory are discharged into an interim hold tank within the Submarine Refit Complex (SRC) void before being transferred to the NUB Chemical Hold Tank. Discharges from the NUB Chemical Hold Tank are routed via the ETP for discharge to the Hamoaze unless there are operational reasons which dictate direct disposal to sewer.

PR

IMA

RY

A

QU

EO

US

W

AS

TE

Primary liquid wastes are routed to the ETP for treatment. These wastes include primary circuit water and waste from workshops and decontamination facilities

Effluent is treated in the NUB ETP prior to discharge into a dedicated pipeline into the Hamoaze.

BPEO Study on Options for Reducing Discharges to Sewer [Reference 6].

Feasibility Study for a Pipeline to Discharge Treated Radioactive Effluent at Devonport Royal Dockyard [Reference 12].

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Description of Waste Arisings Disposal Route BPEO S tudy B

OR

ON

AT

ED

LI

QU

ID

Most of the boronated liquids arise from operations that maintain a high level of criticality safety during defuel/refuel and pre-defuel lay-up.

Low level boronated wastes may be sent for incineration to a facility at Hythe.

Small concentrations of boron may be disposed of to the Hamoaze.

BPEO Study on Management Options for Boronated Liquid Wastes [Reference 8].


OR

GA

NIC

W

AS

TE

Small quantities of waste oil and chemicals are produced from operations within the dockyard. These include waste oil and waste chemicals.

Organic waste is sent to an incinerator in Hythe for disposal.


GA

SE

OU

S Gaseous waste arises from ventilation

extract of plant, rooms and areas where there is potential for airborne radioactivity (e.g. radiologically controlled contamination areas).

Gaseous radioactive waste may be discharged via High Efficiency Particulate Air (HEPA) filters to atmosphere through one of a number of authorised gaseous discharge outlets specified in the Certificate of Authorisation [Reference 15].

BPEO study not considered necessary. [See Section 2.3].

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3. REVIEW OF BPEO REPORTS

The DRDL BPEO reports have been reviewed, the purpose of the review was to ensure that the principles of BPEO had been adopted, and that all parts of the process had been covered appropriately. In conducting the review, the key principles from the EA’s guidance [Reference 1] have been considered. These are as follows:

� Process should be strategic – identifying a preferred overall strategy from the perspective of the environment as a whole;

� The process should be structured and systematic and used to identify and compare strategic options;

� Alternatives should be evaluated in terms of their projected implications for environmental quality;

� Process should involve consideration of environmental effects in the short and long term;

� Effects on the environment are not necessarily restricted to direct emissions of pollutants. Lifecycle considerations such as energy demand may also be considered;

� Consultation should be an integral part of the process.

3.1 BPEO PROCESS

The BPEO process should identify a preferred strategy from the perspective of the environment as a whole, as opposed to detailed optimisation of the selected scheme.

A structured and systematic process should be used in order to identify and compare options. A BPEO study should be an open and transparent process, documented to make explicit the reasoning, data and assumptions.

The DRDL BPEO studies are seen to meet the requirements of the EA guidance. In accordance with the EA guidance [Reference 1], the studies identify the preferred option (or options) without going into detailed optimisation. The process used is structured and is consistent between reviews.

3.2 STAKEHOLDER PARTICIPATION

Consultation is an integral part of the study process; an informed study of alternatives involves taking into account the values and perspectives of a range of stakeholders.

Factors determining the extent of stakeholder participation include:

� Technical and societal significance of the decision;

� Information that stakeholders can bring to the process;

� Extent to which sensitivity analysis to examine the effect of different perspectives is to be included;

� Extent to which stakeholder “ownership” of the process is an objective.

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It is noted that the procedure used for producing BPEO studies for the Devonport site [Reference 17] has been withdrawn. The procedure was used to reflect the BPEO methodology employed by SERCO Assurance, who were contracted to produce the majority of DRDL’s BPEO studies. The procedure stated that the extent of stakeholder participation should be proportionate to the significance of the decision and that BPEO studies should normally include:

� Plant / production manager;

� Health Physics Operations (HPO);

� Safety Case Project Manager (SCPM);

� Environmental Radiation Safety Section (ERSS);

� And whenever possible, someone from Corporate / public affairs.

The involvement of stakeholders for each of the BPEO studies is shown in Table 2. Table 2 - Stakeholder Involvement in BPEO Studies

Stakeholders

BPEO Review Plant / production

HPO SCPM ERSS Corporate / public affairs

Filters / wet sludges

√ √ √ (represented)

√ X

Spent Ion Exchange Resins

Reference to a facilitated meeting – but no minutes or listing.

Ion exchange resin from SSN and TSSBN

No document reference to list of stakeholders.

Solid Low Level and Very Low Level Waste

Reference to a facilitated meeting – but no minutes or listing.

Boronated liquid waste

√ √ √ √ X

Sewers Reference to facilitated meetings – but no minutes or listing.

For future BPEO / BAT studies, the study reports should record who was invited to the study, who attended, and where it was agreed that members of the review panel were considered to be quorate and suitably qualified and experienced [Recommendation 2].

3.3 OPTIONS

Options should be evaluated in terms of their implications for environmental quality. Consideration needs to be given to questions of practicability (including financial costs and / or benefits, as well as wider social and economic considerations), as well as the overall strategic objectives, in order to reflect the wider context in which the decision is being taken.

It is noted that each of the BPEO studies offered a wide range of options. Options have also been compared with discharge routes for other sites (e.g. Sellafield and AWE). Sellafield’s disposal routes are shown in Figure 4. There are no additional options to consider from Figure

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4. AWE’s disposal routes are shown in Figure 5. It is noted that AWE have installed a new treatment plant for radioactive liquid waste. This Waste Treatment Plant (WTP) incorporates an evaporator and reverse osmosis. The activity level of the effluent is reduced to such an extent, that disposal via the trade waste route is acceptable. Evaporation and reverse osmosis have been identified in DRDL option studies [Reference 8]. It is recommended that Babcock monitor the performance and cost of the AWE WTP and check whether this would affect the outcome of their BPEO studies [Recommendation 3].

As a result of this review, no additional options have been identified.

3.4 SCREENING

Decisions are made regarding the principles to be applied in deciding the criteria for screening out options from further consideration, and then the criteria themselves are defined. The criteria are applied in order to select a short list of options from the initial broad list of alternatives.

Each of the BPEO studies was examined to ensure that a list of options was identified prior to screening. Screening doesn’t appear to have been applied in all of the BPEO studies considered here. However, it doesn’t affect the output of the studies but it may have saved time and resource.

For future BPEO studies, consideration should be given to defining a set of essential criteria and then screening out options that do not meet these criteria. This would save time and resource.

3.5 SELECTION OF PERFORMANCE CRITERIA

The performance criteria used in the BPEO studies are considered appropriate. They are consistent between studies, and also with criteria specified by the EA [Reference 1].

The EA expect the “top tier” of complimentary factors that need to be considered as part of a BPEO study to contain:

� Environmental impact;

� Technical performance and practicability;

� Health and safety;

� Social, economic and security considerations;

� Cost.

Such fundamental considerations will be generally valid for any environmental options study, and represent the minimum basis on which it would be reasonable to attach relative weightings as an expression of the values associated with different aspects of performance.

The only factor from the above list that isn’t considered in the DRDL BPEO reports is the “social, economic and security”. Babcock should review the impact of this factor on their BPEO studies {Recommendation 4]. This factor could impact on the outcome of the BPEO studies particularly in studies where the options vary from treatment and direct disposal from site, through to transportation off-site.

3.6 SCORING

Scoring systems within the BPEO studies generally followed the scheme shown in Table 3. It is noted that this scoring scheme was used in the BPEO studies for:

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� Sewer BPEO study;

� Spent resin BPEO study;

� Solid VLLW / LLW.

The schemes used in the other BPEO studies did not seem so well defined. To ensure consistency of approach, it is recommended that the scoring system shown in Table 3 be appropriately updated and used in future BPEO / BAT studies [Recommendation 5].

Table 3 - Typical Scoring Scheme Used in BPEO Studi es

Low (most favourable) Low/Medium or Medium

Medium / High or High

High (least favourable) or not used

Annualised cost

<£300k £300k - £1M £1M - £3M >£3M

Dose to workers

<10 µSv/y > 10 µSv/y and < 1000 µSv/y

> 1000 µSv/y to the Basic Safety

Objective (BSO)

Dose to public < 1 µSv/y < 10 µSv/y and/or < 1 man Sv

< 20 µSv/y > 20 µSv/y and/or > 1man

Sv

Impact on on-site inventory

No significant impact Minor increase / material poses

insignificant management issues

Significant increase / material poses

significant management issues

(e.g. liquids)

Environmental factors

No significant impact Moderate (perceived?) impacts giving rise to possible local concern

Higher (perceived?) impacts giving rise to wider (international /

legal?) concerns

Safety, (construction, operation)

Comparable to (& improvement upon) current

situation / Nuclear Installations Inspectorate (NII) unlikely to express

additional / specific safety concerns

<--> Would require use of unfamiliar equipment / would raise significant

safety concerns

Project risk, tech status, time to implement

Proven technology / option would present no significant technical challenges / highly

likely to be implemented within required timescale

<--> Technical solution not established / requires further Research &

Development (R&D) / unlikely to be implemented

successfully within required timescale

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Consistency with policy, regulatory policy etc

Completely consistent with all current and emergent

policies

Consistent with current policies (especially

national) but not with emerging or likely-to-

emerge and international policies

Inconsistent with significant aspect(s) of relevant policies

3.7 WEIGHTING FACTORS

Weightings are applied to each attribute to reflect its relative importance in establishing a preferred option. If used as part of an analysis, weightings need to be systematically derived and justified. Alternative weighting sets can be used to test the sensitivity of the conclusions to different perceptions of relative importance (e.g. in order to reflect the perspectives of different stakeholder groups).

Table 4 details the weighting factors applied in the BPEO reports. It is noted that the BPEO reports use different weighting factors. For example, it can be seen from Table 4 that the weighting for “Environmental Impact” varies from 1.78 (Low) to 8 (High). As the output from the studies is looking to provide the best environmental option, the scoring for this should be the same (or roughly equivalent) for all examples. For example, the BPEO study for boronated liquid used a “Low” weighting for environmental impact, whereas the BPEO study for sewer discharge applied a “High” weighting.

The weighting associated to particular attributes will also depend upon viewpoint. The BPEO studies reviewed as part of this work include sensitivity studies to determine the effect of different weighting factors depending upon the viewpoint (e.g. plant operator, regulator, member of the public). The sensitivity analyses confirm that the identification of the most favoured option in the base case assessments is not affected by substantial variation in the weighting ratios.

Table 4 - Weighting Factors Used in DRDL BPEO Studi es

Weighting Factors

BPEO Study

Saf

ety

of

wor

kfor

ce &

pu

blic

Rad

iolo

gica

l im

pact

on

publ

ic

Env

ironm

enta

l im

pact

Cos

t

Tec

hnic

al

feas

ibili

ty /

proj

ect r

isk

Tim

elin

ess

Was

te Is

sues

Pol

icy

Sen

sitiv

ity S

tudy

1.78 1 1.78 5.62 10 3.16 5.62 Boronated liquid L VL L H VH M H

Y

3.16 1.78 5.65 3.16 1.78 1 5.62 Filters M L H M L L H

Y

3.16 1.78 5.65 5.62 3.16 1 5.62 Wet Sludges M L H H M L H

Y

2 2 5 5 8 5 8 Resins L L M M H M H

Y

2 2 5 5 8 5 2 Solid LLW / VLLW L L M M H M L

Y

2 8 8 5 5 2 2 Sewers L H H M M L L

Y

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It is noted that the BPEO study for the radioactive waste discharges from the Naval Base [Reference 16] had the highest weight for environmental impact, followed by technical performance and project / programme risk.

3.8 SENSITIVITY ANALYSIS

The effect of alternative weighting schemes has been assessed in all of the BPEO studies considered in this review.

The sensitivity analysis was generally conducted in a way that enabled the perspectives of different groups of stakeholders to be assessed. This approach is considered satisfactory, and it is shown that the outcome of the BPEO studies remained the same.

Comparison of weighting schemes is shown below in Table 5.

Table 5 - Comparison of Weighting Schemes Used in D RDL BPEO Studies

Primary scheme

General manager

Regulator Environmental pressure

group

Plant operator

Safety of workforce and public

L M L M L M

Radiological impact on members of the public

VL L VL L M VL

Environmental impact

L M L M M L

Cost H M H M M H

Tech feasibility / project risk

VH H VH H H VH

Timeliness M M M M H

Waste issues H M H VH VH H

Policy issues H

The output of the BPEO studies remained insensitive to variation in the weighting scheme.

3.9 UNCERTAINTY

Uncertainty should be addressed in a BPEO study. This should include a clear statement setting out the way in which different sources of uncertainty have been dealt with, and for transparent and realistic treatment of its implications within the analysis.

Typical sources of uncertainty in BPEO studies include:

� Uncertainty regarding the most appropriate scope and framework of attributes, rankings and weightings that will genuinely indicate the most practicable choice from a range of environmental options

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� Uncertainty regarding the validity of models and data, including statistical variability, used to compare options

� Uncertainty concerning the validity of assumptions embedded within the analysis, including assumptions about future developments in regulatory and policy frameworks etc

� Project risks, including uncertainty about costs, practicality and timescales.

The BPEO studies reviewed as part of this work do not cover uncertainty. However, it is recognised that the sensitivity studies within most of the BPEO studies do allow for variations in scoring and / or weighting. It is recommended that sources of uncertainty, and the effect of uncertainty on scoring and weighting is identified in future BPEO / BAT studies [Recommendation 6].

3.9.1 Summary

In general, the BPEO studies provided by Babcock follow the key principles of the EA’s guidance [Reference 1].

However, the BPEO studies reviewed do not include assessment of social, economic and security issues. This does not comply with the EA guidance.

Relevant stakeholders have been involved in the BPEO studies although in some instances a listing of stakeholders is not provided. For future reviews the study reports should provide details of invitees, attendees and a statement on the fact that the attendees cover the appropriate disciplines and are SQEP.

The process for identifying options, screening, performance criteria, scoring and weighting is carried out in accordance with the EA guidance.

The BPEO reviews do not consider uncertainties, and some do not specify gaps in knowledge. For future reviews, any significant uncertainty associated with each option and their performance criteria should be identified.

The sensitivity studies carried out for each BPEO review are extensive and cover the effect of variations in scoring and weighting from different stakeholder perspectives. It is noted that the sensitivity studies do not change the outcome of the BPEO reviews.

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4. REVIEW AGAINST BAT

The BPEO studies for some of the waste streams considered as part of this study date back to 2001. It is necessary to ascertain that these studies have considered the necessary information to meet the requirements of the newer BAT standards. This will also allow for Babcock to demonstrate that they are practising to the current standards where they currently do so. It is understood that there will be certain areas where the older methodologies will not have adequate information, but the EA recognise this and allowances will be made for a transition over time to update the methodology used. The BAT process is illustrated in Figure 1.

BAT is broadly the same concept as BPEO and BPM and delivers the same level of environmental protection. Where operators are already using BPM/BPEO, they will therefore satisfy the requirements of BAT at the date of change to BAT. Nuclear operators may choose to continue using their existing procedures, although changes to reflect the adoption of BAT will be required in due course [Reference 2].

The following principles are documented in the consultation draft of the Radioactive Substances Regulation Environmental Principles:

� The best available techniques should be used to ensure that production of radioactive waste is prevented and where that is not practicable minimised with regard to activity and quantity (Radioactive Substance Management Developed Principle (RSMDP) 3) [Reference 18].

� The best available techniques should be identified by a methodology that is timely, transparent, inclusive and based on good quality data and properly documented. (Principle RSMDP4) [Reference 18].

� In all matters relating to radioactive substances, the “best available techniques” means the most effective and advanced stage in the development of activities and their methods of operation. A technique will not be BAT if its costs are grossly disproportionate to its environmental benefits. Costs include time, trouble, money and all other resources. All benefits and potential benefits should be taken into account. Where a statutory obligation requires stricter conditions and limits than those achievable by the use of BAT, then additional measures should be applied. In determining BAT, an operator needs to achieve a balance across safety and environmental, societal and economic issues. (Principle RSMDP6) [Reference 18].

� When making decisions about the management of radioactive substances, the best available techniques should be used to ensure that the resulting environmental risk and impact are minimised. (Principle RSMDP7) [Reference 18].

It is noted that Babcock do not have a BAT methodology in place. To ensure compliance with EA regulations, a BAT methodology needs to be produced. It is recommended that the BAT methodology also confirms ownership of the future BAT studies [Recommendation 7].

As part of this BPEO review, the BPEO studies have also been reviewed against the BAT process. The review of BPEO studies against the BAT requirements is summarised in Table 6. The BAT process has been designed to bring BPM and BPEO together into one document. This review has focussed on the BPEO requirements.

In general, the BPEO studies follow the requirements of the BAT process shown in Figure 1 [Reference 22]. The one area where BAT process does not appear to have been followed is in

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the identification of uncertainties and knowledge gaps. As Babcock move towards adopting the BAT process, this should be considered in future studies [Recommendation 8].

Proportionality has been adopted in the BPEO studies, and the level of effort expended to resolve an issue, and record the selection process, is seen to be proportionate to the range of options available, and the extent to which precedent and established good practice can be used to assist the decision making process.

Figure 1 - Flowchart for delivering BAT [Reference 22]

Is a BAT study required?

Assemble delivery team

Involve stakeholders?

Identify & characterise options

Document project constraints and assumptions

Screen out non-viable options

Determine relevant approach for remaining options

Proportionality

Characterise options

Qualitative assessment (based on good practice and precedent)

Quantitative assessment

(numerical comparison of options)

Identify uncertainty and knowledge gaps

Is information important to

demonstration of BAT?

Identify BATReport study findings

Decision making

Implement, maintain & review performance

Identify issue

N

Y

N Y

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5. REVIEW OF EARWG DATABASE

EARWG was set up in recognition of the EA requirement for operators to provide review reports to the EA under RSA93 authorisations. Representatives share radioactive waste management practices and developments and discuss the application of best practice in waste minimisation with colleagues undertaking similar roles across the industry.

A comprehensive review of the EARWG database has not been carried out. Review of the database has shown that the database is aimed at waste minimisation processes, such as methods for encapsulating waste. The benefit in conducting a comprehensive review is better placed within the BPM review that is being carried out in parallel to this BPEO review.

In the future, BPM and BPEO would both be encompassed by BAT reviews. Therefore, future reviews should be against BAT rather than BPM and BPEO.

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6. IMPACT OF BPEO REVIEW

The IWS for the Devonport site, [Reference 19], provides an overview of the strategy adopted for each waste stream with reference to supporting documentation including BPEO studies. As BAT has now replaced BPEO, the IWS will need to be updated to reflect change in policy and to reference out to BAT studies [Recommendation 9]. The EA may then choose to review the IWS rather than individual BAT studies.

This study demonstrates that all of the waste streams have appropriate BPEO studies in place, and that the best option(s) are being utilised. However, a review of a number of DRDL Safety Cases indicates that Plant Safety Cases do not always make the case that waste streams are being processed in accordance with BPEO.

A number of DRDL Plant Safety Cases are also being updated following Periodic Review of Safety. These safety cases shall demonstrate that radioactive waste streams are processed in accordance with BPEO / BAT.

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7. RECOMMENDATIONS

Number Recommendation

1 The BPEO study for the management of core pond furniture should be revisited and modified to allow for all contaminated metals.

2 For future BPEO / BAT studies, the study reports should record who was invited to the study, who attended, and where it was agreed that members of the study panel were considered to be quorate and suitably qualified and experienced.

3 Babcock should monitor the performance and cost of the AWE WTP and check whether this would affect the outcome of their BPEO studies.

4 Babcock should review the impact of the “social, economic and security” factor on their BPEO studies.

5 It is recommended that the scoring system shown in Table 3 be used in future BPEO / BAT studies.

6 Sources of uncertainty, and the effect of the uncertainty on scoring and weighting should be identified in future BPEO / BAT studies.

7 Babcock should produce a BAT methodology. The methodology should seek to confirm ownership of future BAT studies.

8 Uncertainties and knowledge gaps should be considered in future BAT studies.

9 The IWS should be updated to reflect future changes in policy and to reference out to BAT studies.

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8. CONCLUSIONS

This report provides a comprehensive review of DRDL’s current radioactive waste disposal / discharge routes to assess whether they represent the BPEO for waste disposal from the site.

It is noted that the BAT process has now replaced BPEO. Recommendations are made within the report to ensure that Babcock comply with the requirements of the BAT process, that they produce a BAT methodology, and that documentation (e.g. IWS) is updated to reflect changes in policy and studies as they become available.

This review confirms that, with the exception of the gaseous discharge route, BPEO studies exist for all of DRDL’s waste streams. Given that discharge of gaseous waste to the environment is a straightforward route, with few options, it is considered that a BPEO is not required for this discharge route.

The process for identifying options, screening, performance criteria, scoring and weighting is carried out in accordance with the EA guidance. Relevant stakeholders have been involved in the BPEO studies although in some instances a listing of stakeholders is not provided. For future BPEO (or BAT) studies, the study report should contain a listing of stakeholders and a statement on the fact that they cover the appropriate disciplines and are SQEP [Recommendation 2].

It is noted that the BPEO studies do not explicitly cover “social, economic and security” impact. This is one of the “top tier” of factors that the EA expect to see considered as part of a BPEO study. Therefore, Babcock should review the impact of this factor on their BPEO studies {Recommendation 4]. This factor could impact on the outcome of the BPEO studies particularly in studies where the options vary from treatment and direct disposal from site, through to transportation, treatment and disposal off-site.

It is noted that the BPEO reviews do not consider uncertainties, and some do not specify gaps in knowledge. However, this doesn’t undermine the value of the BPEO studies. Each of the BPEO studies provides a set of assumptions and these are generally based on referenced data from site (e.g. radionuclide concentrations, volumes and radiological assessments). Assumptions have also been made on the continued availability of facilities (for example, encapsulation and compaction at Winfrith). There will be some uncertainty associated with this, but if a particular disposal route does become unavailable then the BPEO study would be revisited to determine the next best option. For future reviews, any significant uncertainty associated with each option and their performance criteria should be identified [Recommendation 6]. If the option study panel cannot identify any significant uncertainties in the supporting information, then a statement confirming this should be included within the study report.

The sensitivity studies carried out for each BPEO review are extensive and cover the effect of variations in scoring and weighting from different stakeholder perspectives. It is noted that the sensitivity studies do not change the outcome of the BPEO reviews.

It is noted that the BPEO reports use different weighting factors. For example, the weighting factor for environmental impact varies from 1.78 (low) for the boronated liquid BPEO study, to 8 (high) for the sewer discharge BPEO study. However, the sensitivity analyses confirm that the identification of the most favoured option in the base case assessments is not affected by substantial variation in the weighting ratios.

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In general, the BPEO studies follow the requirements of the BAT process shown in Figure 1. The one area where the BAT process does not appear to have been followed is in the identification of uncertainties and knowledge gaps. As Babcock move towards adopting the BAT process, this should be considered in future reviews [Recommendations 6 and 8].

Proportionality has been adopted in the BPEO studies, and the level of effort expended to resolve an issue, and record the selection process, is seen to be proportionate to the range of options available, and the extent to which precedent and established good practice can be used to assist the decision making process.

The review confirms that the approach taken to BPEO study is appropriate, and the options provided by DRDL for the disposal of radioactive waste remain the BPEO for the site.

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9. REFERENCES

Title Date Document reference

1. Guidance for the Environment Agencies’ Assessment of Best Practicable Environmental Option Studies at Nuclear Sites

February 2004 N/A

2. Environment Agency, Radioactive Substances Regulation : Principles of Optimisation in the Management and Disposal of Radioactive Waste

April 2010 N/A

3. OSPAR

N/A www.ospar.org

4. Royal Commission on Environmental Pollution. Command 310, 12th Report Best Practicable Environmental Option (BPEO).

February 1988 N/A

5. BPEO Study on Management Options for

Solid Low Level and Very Low Level Waste

March 2005 SA/SMS-14932/R01, Issue 1

6. BPEO Study on Options for Reducing Discharges to Sewer

April 2003 SA/SMS-14932, Issue 1

7. BPEO Study on the management Options for Filter and Wet Sludge Waste Streams

February 2009 DNSQ-REP-1840

8. BPEO Study on Management Options for Boronated Liquid Wastes

May 2007 SA/SMS/18749/R001 Issue 1

9. BPEO Study on Management options for Spent Ion Exchange Resin

June 2005 SA/SMS-14932/R02, Issue 1

10. Spent Radioactive Ion Exchange Resin

Arising from SSN and TSSBN Reactor Plant Decontamination and On Board Primary Coolant Treatment at Devonport Royal Dockyard- Phase 2 Report – Option on Strategy Selection.

December 2002 RWMD(02)PO94

Issue 2

11. Application for a Variation to DRDL’s Authorisation for Disposal of Radioactive Waste from Devonport Royal Dockyard

N/A Enclosure to DNSQ-NAG-QU34 (406-008/08)

12. Feasibility Study for a Pipeline to Discharge Treated Radioactive Effluent at Devonport Royal Dockyard – Best Practicable

Environmental Option Study

July 2008 DNSQ-REP-1810

13. Strategic BPEO for Metal Waste Management – Options Evaluation.

11 April 2006 JF\260705\NDA\ENG01

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Title Date Document reference

14. Options Study for the Management of Core Pond Furniture

January 2008 810126482

15. Radioactive Substances Act 1993, Authorisation Variation no :

AN7104/CC3093.

1 May 2009 AN7104/CC3093

16. BPEO Study for Radioactive Wastes discharged from the Naval Base

21 May 2009 NBC/BY9922/BPEO

ISSUE 01

17. Best Practicable Environmental Option Study Methodology1

August 2007 FP19-08-000, Rev B

18. Radioactive Substances Regulation – Environmental Principles. Regulatory Guidance Series

April 2010 RSR1

19. Integrated Waste Strategy for the Devonport Site

April 2010 000008538

20. Sellafield Radioactive Waste Disposals: Consultation on proposed changes to permit

January 2010 Environment Agency

21. Certificate of Authorisation and Introductory Note: Disposal of Radioactive Waste from Nuclear Site. AWE plc

March 2007 BZ1994

22. Best Available Techniques (BAT) for the Management of the Generation and Disposal of Radioactive Wastes – A Nuclear Industry Code of Practice

December 2010 N/A

1 Note that this procedure was withdrawn in July 2010.

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Table 6 - Review Against BAT Requirements

Titl

e of

Doc

umen

t

Iden

tify

and

Cha

ract

eris

e O

ptio

ns

Scr

een-

out N

on-V

iabl

e O

ptio

ns

Det

erm

ine

Rel

evan

t App

roac

h fo

r R

emai

ning

Opt

ions

App

ly P

ropo

rtio

nalit

y

Cha

ract

eris

e O

ptio

ns,

Qua

litat

ive

/ Qua

ntita

tive

Ass

essm

ent

ID u

ncer

tain

ty a

nd K

now

ledg

e G

aps

Rep

ort S

tudy

Fin

ding

s

Dec

isio

n M

akin

g

BPEO Study on Management Options for Filter and Wet Sludge Waste Streams

� p9-12

� p9-12

tables 2-5

� P20 �

� Tables 2-5, 7 & 9

p46 p48 table 10

p49 p51 table 14

p54-57

X �

Section 7

� Throughout document

BPEO Study on Options for Reducing Discharges to Sewer �

Section 3.5

Screening is stated as being conducted (p.6) but there is no

evidence of this within the report.

� Section

3 �

� Section 4.3

Tables 7 & 8

� Section

6

� Section

5

� Tables 6 and

7

BPEO Study for Radioactive Wastes discharged from the Naval Base �

section 3.2

� section 4

� Section

3

This report doesn’t appear long enough to deal with all waste from the Naval Base.

� Tables 6, 7, 8

� p 7

� section

4 �

BPEO Study on Management Options for Solid Low Level and Very Low Level Waste

� section

4.1 p vii

Not felt necessary to screen any options out. (p.7)

� Section

3

Level of detail sufficient as it is only

dealing with two waste streams.

� Section 4.3 Appendix A

X � �

Throughout Document

BPEO Study on Management Options for Spent Ion Exchange Resins �

p vii p13 & 14

Not felt necessary to screen any options out. (p.10)

� Section

3 �

� section 4.3 X � �

Spent Radioactive Ion Exchange Resin Arising from SSN and TSSBN Reactor Plant Decontamination and On Board Primary Coolant Treatment at Devonport Royal Dockyard- Phase 2 Report- Option on Strategy Selection

This is a short report that looks to be part

of a larger document. X �

BPEO Study on Management Options for Boronated Liquid Wastes

� p 11 p23

p 36-38

� p 36-38

� p 18-

22 �

� P11, 23

Section 4.3. Figures 4-7

(limited compared with other studies)

X � �

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Figure 2 - Liquid Radioactive Waste Discharge Strea ms

Notes:

Discharges from the NUB Chemical Hold Tank can be routed to the NUB ETP for discharge to the Hamoaze or to the dockyard sewer. DRDL’s current strategy is to discharge Chemical Hold Tank contents to the NUB ETP thereby meeting the BPM requirement implicit within DRDL’s Certificate of Authorisation. Aqueous wastes also arise from operations at a number of wharfs. These wastes are handled through installed effluent tanks, PETs and Jet Vacs.

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Figure 3 - Solid Radioactive Waste Disposal Streams

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Figure 4 - Main Disposal Routes for Radioactive Was te from Sellafield Site [Reference 20]

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Figure 5 - Main Disposal Routes for Radioactive Was te from AWE [Reference 21]




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