RWMAC report on MoD radioactive waste practices

7. THE ATOMIC WEAPONS PROGRAMME

Management of AWE activities

Historical development

7.1 The Atomic Weapons Establishment (AWE) sites at Aldermaston and Burghfield in Berkshire undertake the design, manufacture and servicing of Trident nuclear warheads, conduct research and development into warhead technology and carry out decommissioning of redundant Chevaline nuclear warheads and associated process plants. AWE was brought under the control of contractorised management carried out by Hunting-BRAE Ltd in April 1993. The Secretary of State for Defence decided unilaterally that the disapplication of RSA93 to AWE should be lifted and, hence, site arrangements for disposal, including discharges, of radioactive waste were brought within the scope of authorisation under RSA93 at the same time. After satisfying various operational reviews initiated by NII, the two sites were licensed under NIA65 in July 1997.

7.2 RMWAC's perception at the time of its last report on defence wastes was that AWE was undergoing a significant cultural change as a result of management contractorisation and the introduction of civil regulatory controls. RWMAC's overall view of the period since 1997 is that contractorisation has not had any prejudicial effect on the nuclear security of the sites, and, while a number of historic problems have not yet been solved, some significant benefits have accrued. These include improvements in a number of aspects of radioactive waste management and site decommissioning and clean-up work, and greater transparency in regulation, delivered through the application of the civil legislation. While the Committee believes that the higher standards waste management achieved can be attributed, to a significant part, to the introduction of civil regulatory controls, the role played by Hunting-BRAE has also been important. MoD must now ensure that past progress in improving radioactive waste management and site decommissioning and clean up at AWE is carried forward and built upon by the present contractor - AWE Management Limited (AWEML).

New contractual arrangements

7.3 Hunting-BRAE's management contract came to an end, after seven years, on 31 March 2000. The new management contract was awarded, following competitive tender, to a new contractor - AWEML - for an initial period of 10 years.

7.4 The change in contractor was accompanied by radical changes to the nature of the contractual undertaking itself. The original contract between Hunting-BRAE and MoD was based on detailed specification of the work requirements, detailed scrutiny of their implementation by the Ministry and, correspondingly, relatively limited discretion on the part of the contractor either to reformulate or realign programmes, or to change the manner through which they were delivered. By contrast, AWEML has been contracted on the basis that it will, for the contract price, "run the business" of delivering the nuclear weapons programme, including associated research, and the decommissioning of redundant weapons. Other site-related activities, including radioactive waste management, are required by the contract, but are not defined or resource-planned in detail.

7.5 The new contract, at present covering the period to 2010, is output driven and incentivised, with regular performance reviews. Unlike Hunting-BRAE, AWEML has been given freedom to identify and prioritise waste management and site decommissioning projects within the overall price of the contract, specifically so as to avoid the need for detailed oversight of a large number of individual projects by MoD.

7.6 Instead, the contract is predicated on the achievement of "payment milestones" and "performance measures", details of which are discussed in Annex 7. RWMAC visited AWE in February 2000, met AWEML in May 2000 and MoD's Nuclear Weapons Integrated Project Team (NWIPT) in January 2001. It was clear from the various discussions that these arrangements were subject to a trial and learning period during the first year of the contract. It is foreseen that both the milestones and performance measures, which are formulated on a year-by-year basis, will change in character, from review and preparation to actual implementation of work, and thereby, in MoD's view, become more demanding in future years as AWEML increasingly gets to grips with the nature of its task.

7.7 It is important to understand the impact that the regulatory process has had on the approach taken by AWEML, both before and after its takeover of the management contract. For instance, in granting new authorisations to dispose of radioactive wastes at the time of contract takeover, EA not only specified revised discharge limits, but also that a number of reviews and operational improvements should be carried out. NII presentations, and its consideration of the contract tender prospectuses helped to inform the process. Both EA and NII were committed to review the new management arrangements at its commencement and then at three, and twelve, months after contract award. AWEML retains its own independent safety advisor and he also carried out three and twelve month reviews. MoD's contract management organisation for the nuclear weapons programme, NWIPT, undertakes regular review of the operation of the contract. While the civil regulators have no formal input to specification of the performance measures applied by NWIPT, their views can be fed in by NWIPT.

7.8 Based on discussions with MoD and AWEML, RWMAC believes that, in principle, the new AWE management contract can be used to achieve the necessary standards and objectives in respect of radioactive waste management and site decommissioning and clean-up. But there are, in the Committee's view, several important issues that need to be considered in this context. Notably, MoD needs to be certain, by means of the incentive arrangements at its disposal, that sufficient assurance can be provided of the adequacy of AWEML's radioactive waste management and decommissioning plans, and their implementation, bearing in mind the decision to adopt a more arms-length approach in its relationship with the contractor. This may not be such an issue in the current initial acclimatisation period, but could become so in future, if, for any reason, the financial margins built in by AWEML were to come under pressure. In this context, the Committee is aware of the slippage that has occurred in previous AWE radioactive waste management projects in the past. In the shorter term, there is also the issue of the consistency of AWEML's radioactive waste management and decommissioning plans compared with those of Hunting-BRAE, and the need to declare openly the reasons for any significant change from them.

7.9 To summarise, RWMAC believes that MoD must use the controls at its disposal to ensure that appropriate priority continues to be given to radioactive waste management, and site decommissioning and clean-up, in setting performance targets for AWEML under the contract arrangements. This recommendation is made against the background of the greater freedom given to the contractor under the new arrangements - for which the main emphasis is on nuclear weapons work. But in addition - for reasons outlined in section 4, paragraph 26 and expanded in subsequent parts of this present section - RWMAC also believes that while the contractual arrangements and the application of civil regulation have both been beneficial, they cannot be regarded as substitutes for MoD to have in place some means of its own for anticipating difficulties in the discharge of its responsibilities as owner of the sites' radioactive wastes.

Waste management planning

7.10 From scrutiny of the documentation made available, it appears to RWMAC that Hunting-BRAE's work to formulate strategies and plans for radioactive waste management and site decommissioning was essentially sound in conception and execution. The company produced high-level strategies for waste management and decommissioning, which were reviewed and revised annually, and issued to the regulators. Its forward planning process was thorough and robust with detailed attention given to the timing and prioritisation of projects. These waste management and decommissioning plans reflected clearly set out, if somewhat broadly-based, company policies in each case. The company's Waste Management Organisation was also able to demonstrate a well-focussed internal view of key objectives over two, five, and ten-year periods.

7.11 A major criticism made of Hunting-BRAE management in the last RWMAC report concerned the lack of focus on the timeframe for the Nirex ILW repository. At the time this meant, in the Committee's view, that the organisation was not in a position to respond well to slippage in the Nirex programme, particularly where there was a potential impact on provision for ILW storage at its sites. In practice, the collapse, in 1997, of the ILW disposal programme placed the relationship between AWE and Nirex in a completely new context - requiring, as at other major sites, a fresh view to be taken of on-site storage of ILW and of LLW unsuitable for disposal to Drigg. Hunting-BRAE initiated a comprehensive review of ILW in storage at Aldermaston and began the construction of a new ILW store. There have also been improvements to existing storage arrangements and waste packaging, with provision for regular checking and monitoring of stocks. These initiatives should be progressed to completion. It will, however, be important for AWEML to review, at some appropriate point, how the design life for packaging and stores (said by the company to be 25 years) dovetails with the outcome of the forthcoming Government review of UK radioactive waste management policy and, as part of a new policy, the timeframe for establishing a management route for ILW.

7.12 It is clear to RWMAC that, as part of the process of contract takeover, AWEML needed to review the existing Hunting-BRAE strategies and plans, and to consider how its own overall strategy for the sites could be implemented (a key area being its proposals for injection of other forms of private funding facilitated by extension of the contract to 25 years). An important element in the company's approach appears to be its high-level combined radioactive waste management and decommissioning plan, of which RWMAC saw a first draft. It is understood that the report has now been approved by the NSC and sent to the regulators.

7.13 RWMAC welcomes the AWE radioactive waste management and decommissioning plan, which now needs to be finalised and publicised as soon as possible. It is also important that any significant differences from the previous Hunting-BRAE plans are made clear, both to secure public confidence and avoid giving any impression of procrastination (since at the time this report was published, more than a year had elapsed since AWEML took over). The plan needs to be consistent with both approved performance measures, and timing objectives, in order that progress and performance can be monitored. In RWMAC's view, it is important, both for AWEML and MoD, to demonstrate through such plans that the improvements that have been achieved in recent years can be sustained and carried forward.

7.14 For reasons given in Annex 7, RWMAC is supportive of the concept of forwarding-looking vision statements for sites such as AWE. Such statements appear to have been a feature of recent planning for the site. As well as pointing a clear way forward, the Committee feels that such statements are important in giving the public and stakeholders, as well as the operator's staff, a picture of the way in which management sees future strategic development of the site. To succeed in this, all such documents must be framed in language that can be understood by outside groups as opposed to internal experts.

7.15 RWMAC would like to see further progress made towards passive storage of waste and continuing reduction in the amount of unconditioned sludges and liquid wastes held on the AWE sites. The Committee supports, for example, the objective stated in one current ten-year vision statement, shown to the Committee during the visit, that no unconditioned wastes should be in store for more than three months. This, in RWMAC's view, exemplifies the positive impression of waste management at the site that can be conveyed through such vision statements. Continued progress with the minimisation of radioactive waste arisings, in the context of the extensive decommissioning work planned, is also important.

7.16 Whilst recognising the resource-constrained nature of the activity, better characterisation of site contamination at AWE is a clear and urgent task for AWEML. Within this, resolution of the extent to which the sources of tritium contamination can be identified will be particularly important. The radiological implications of tritium may be small, but this issue has acquired considerable significance in presentational terms. At the very least, AWEML needs to mount a convincing demonstration that the nature of site contamination is understood and that, where practicable, levels are to be progressively reduced over coming years. RWMAC would also like to see satisfactory completion of the Southampton University study of radioactivity levels around the Aldermaston and Burghfield sites, and its circulation, in a readily understandable form, to local communities. AWEML has commented that, in its view, the source of tritium in groundwater is now much better understood and levels of activity are decreasing. The company has confirmed that the Southampton University study is nearing completion and the results will be made widely available.

The Pangbourne pipeline

7.17 The Pangbourne Pipeline, which discharges the bulk of Aldermaston's treated radioactive liquid effluent into the Thames, was described in detail in the last RWMAC report. Following public consultation, the central feature of which was the proposed closure of the pipeline and its replacement with evaporator and alternative technologies, EA decided, as part of the new RSA93 authorisation granted in March 2000, on closure by 2005. In general, RWMAC welcomes the strategic approach adopted by EA in the new authorisation. The Committee does, however, have serious reservations concerning the way the pipeline closure decision was taken.

7.18 RWMAC's main concern is not the closure of the pipeline itself, which had clearly been a matter of local concern for a number of years, but rather the processes by which the decision was arrived at. The evaporator is not a means of removing tritium, the predominant radionuclide in the effluent, and merely substitutes its airborne discharge for its release in liquid form. Evaporation will, however, remove other radionuclides, such as plutonium and uranium. In practice, the choice between the two disposal routes is thought to be relatively finely balanced. But what is also important, in RWMAC's view, was that the decision to close the pipeline lacked clarity in the way in which EA interpreted the various radiological protection principles, such as BPM, BPEO and ALARA. RWMAC pressed EA, without success at the time, for more information on the manner in which decision-making process had been carried out. In particular, it is unclear, from the available information, whether the doses from proposed new schemes, however minuscule, were adequately compared with the status quo of retaining the pipeline. RWMAC continues to believe that regulatory decision-making must be open and transparent and, so far as is reasonably practical, understandable to those whom the regulation is designed to protect.

7.19 Development of new facilities to achieve reduction in off-site discharges, in the wake of closure of the Pangbourne Pipeline, needs to be monitored closely by MoD, in conjunction with EA, to ensure that doses to the public are kept as low as reasonably achievable (ALARA) and those to the workforce are as low as reasonably practicable (ALARP). RWMAC believes, for example, that if AWEML was to secure regulatory approval for the use of evaporator technology, it would need to consider carefully how washout of tritium from stack discharges might affect levels of radioactivity elsewhere on the site and the surrounding area. There is, in addition, the future of the pipeline structure itself. RWMAC understands that AWE has carried out a BPEO study for decommissioning the pipeline. This concludes that the BPEO will be to clean the pipeline out, grout it and then to leave it undisturbed. RWMAC supports the concept of work aimed at determining the nature of decommissioning on the basis of removing present and potential radiological hazards and providing acceptable assurance of present and future safety. The Committee assumes that implementing the BPEO would need regulatory approval.

7.20 Not least because of current uncertainties about the origin of tritium, RWMAC has already said⁸ that it doubts that the reduction, by 2010, of total beta/gamma liquid discharges from weapon nuclear production at AWE (including tritium) to zero, as proposed by the Government in the National Discharges Strategy⁵, is actually achievable. That said, the Committee believes that substantial reductions, at least, should be practicable.

MoD internal oversight of activities at AWE

7.21 Civil regulation, under NIA65 and RSA93, applies to virtually all operations at AWE (the only exception being some aspects of final nuclear weapon assembly at Burghfield). Oversight of the AWE management contract falls to NWIPT. This responsibility includes scrutiny of plans for radioactive waste management, and site decommissioning and clean-up. In view of the key issues that will be raised, and core deliverables that will be required of AWEML over the next few years, MoD needs to ensure that it has sufficient expertise available to provide the necessary internal "assurance" required on such matters, bearing in mind the adoption of a more hands-off approach through the new contract.

7.22 As will have been clear from section 4 of this report, RWMAC has recommended that MoD should consider the establishment of a new body to provide the Secretary of State for Defence with the necessary assurance and regulatory mechanisms consistent with his, or her, position as owner of the wastes. This body would cover the three main areas of defence work giving rise to issues of nuclear safety and radioactive wastes - the NNPP, the nuclear weapons programme, and MoD's use of radioactive sources. Arguably, the most important of these areas is the nuclear weapons programme. RWMAC is aware that, to a degree at least, these responsibilities reside with a separate "compliance" group within NWIPT (the compliance team itself having no responsibility for setting programme outputs). But, in RWMAC's view, it is still questionable whether, in carrying out this function, NWIPT can adequately separate out its operational role (i.e., for commissioning and controlling the delivery of weapons) from the need for assurance on issues raised by radioactive waste management. Nor (for the reasons set out in section 4, paragraph 26) is RWMAC convinced that reliance on the civil regulatory process can, by itself, provide the necessary forewarning of potential difficulty.

Communication with the public

7.23 It is clear that arrangements were put in place during Hunting-BRAE's contract tenure to improve liaison with the local community with the aim of promoting better understanding of AWE's work and public confidence in its operations. These initiatives must be taken up and built upon by AWEML. There are indications that the company is responding positively to this challenge.