ENG04 Specification and guidance on the content and format of an Integrated Waste Implementation Plan

Question 1

1. Preface

Accepted Answer

This document provides the specification and guidance for an Integrated Waste Implementation Plan (IWIP). This will retain and build upon the fundamental elements of the specification and guidance for an Integrated Waste Strategy (IWS) to ensure that plans for implementation of the strategy are developed and documented. The production of an IWIP will help to facilitate the integrated management of waste across the NDA estate by identifying opportunities, dependencies and synergies, and scope for collaboration across the NDA estate and the wider nuclear sector.

An IWIP will ensure that there is a clear thread from Her Majesty’s Government (HMG) and Devolved Administrations (DA) policies, through NDA and site waste strategies, to the implementation of site waste management plans. Such a thread will enable the beneficial development of each to be influenced by the other, facilitated by a clear flow of information between relevant stakeholders and authorities. This enables Site License Companies (SLCs) to actively influence the future decision-making process, providing a clearer understanding and visibility to the NDA of the current and future site/estate needs.

It is recognised that much of the requested information may already be available elsewhere within site documentation (e.g. extant IWS), hence the IWIP may “signpost” relevant information that has been produced for other purposes. The IWIP will provide a narrative to describe ongoing and future planned work to implement that strategy, as well as identifying relevant risks and opportunities, both site and estate wide.

This specification describes the aims of an IWIP and provides guidance on what it should include and how it should be used. The specification is intentionally non-prescriptive. Instead, it builds on first principles, considering what a combined strategic and planning document should be and what it should include. SLCs are encouraged to utilise their IWS/strategic arrangements to develop their IWIP and make best use of any existing documents and processes, where possible.

Question 2

2. Introduction

Accepted Answer

2.1 Purpose

This document provides the specification and guidance for an Integrated Waste Implementation Plan (IWIP). The IWIP retains and builds upon the fundamental elements of the Integrated Waste Strategy (IWS), as was the focus of the earlier (2012) version of ENG01 and ensures that plans for implementation of the strategy are developed and documented (Figure 1). The IWIP should be consistent with the IWS and the two may be combined to enable a consolidated presentation of the strategic and implementation planning aspects.

Flow diagram listing the contents of an Integrated Waste Implementation Plan. — Figure 1: Contents of an Integrated Waste Implementation Plan.

ENG01 IWS Specification and guidance 2012	ENG04 Specification and guidance 2022
Integrated Waste Strategy Principally the IWS seeks to answer three key questions relating to waste management: 1. Where are we today? 2. Where do we want to get to and when? 3. What actions are needed to get there?	Integrated Waste Implementation Plan (IWIP) New specification to ‘absorb’ previously produced IWS Implementation plan for NDA’s strategy Implementation of SLC’s strategy Via the IWIP, SLC’s can refer, explain and describe their own strategies and how these will be implemented

The overall purpose of the IWIP is to facilitate and promote better waste management both at the site level and across the NDA estate by achieving several subordinate aims:

To ensure there is a clear link between Her Majesty’s Government (HMG) and Devolved Administrations policies, NDA and site waste strategies, and the implementation of site waste management plans. Thereby, to enable the development of each to be influenced by the others in a flow of information between relevant stakeholders and authorities
To enable a clearer demonstration of how NDA Strategy^{[footnote 1]} is being implemented and its alignment with the Integrated Waste Management principles
To facilitate NDA’s own planning and prioritisation and to provide NDA with clear evidence of progress in the implementation of its programme
To provide NDA and HMG with clear up-to-date information upon the current position regarding waste management across the NDA estate
To act as a coherent, transparent strategic stakeholder communication tool
To inform NDA IWM Strategy, and better coordinate waste management activities and plans across the estate by early identification & implementation of programmes, projects, initiatives, needs, risks, opportunities and synergies

It is recognised that much of the requested information may already be available elsewhere within site documentation, hence the IWIP can “signpost” this information such that it is easily identifiable and collatable. The IWIP should provide a narrative to describe ongoing and future work activities to deliver the strategy, and to identify relevant risks and opportunities.

The IWIP approach embraces the IWM principles and should demonstrate how these principles are being applied, such as how the Waste Hierarchy is being enacted and how “wider UK strategic initiatives” are followed and implemented. It also reflects stakeholder views and experiences, including practitioner learning relating to the creation, value and effectiveness of an IWS. These views were captured from a “Strengths, Weaknesses, Opportunities and Threats” (SWOT) exercise undertaken with Site License Companies (SLCs) and regulatory bodies and development of this specification and guidance document has been informed by stakeholder workshops – the ‘IWS Specification Replacement 1st and 2nd Project Workshops’, held virtually in December 2021 and February 2022, respectively.

The Integrated Waste Management principles:

Supporting key risk and hazard reduction initiatives by enabling a flexible approach to long-term waste management.
Taking into consideration the entire waste management lifecycle, including how it supports other NDA or wider UK strategic initiatives, such as large-scale decommissioning programme.
Applying the Waste Hierarchy, which is recognised as good practice and should enable an effective balance of priorities in waste management decisions, including value for money, affordability, technical maturity, and the protection of health, safety of the environment.
Promoting timely characterisation and segregation of waste, which underpins effective waste management from the outset.
Where appropriate, provide leadership by encouraging greater integration across the estate and supply chain, in particular by seeking opportunities to share treatment facilities, interim storage assets, capabilities and learning.
Supporting and promoting the use of robust decision-making processes to identify the best options for waste management.
Enabling the availability of sustainable, robust infrastructure for continued operations, hazard reduction and decommissioning.

2.2 Scope

The IWIP should consider all wastes as defined in the NDA’s IWM Strategy^{[footnote 3]}, including non-radioactive wastes. It should demonstrate how the Integrated Waste Management principles are being implemented in practice. The IWIP should address all currently foreseen waste management activities up to end of mission by setting out the facilities and plants that are required to manage waste through the lifecycle (i.e. through construction, operation, decommissioning, treatment, storage and disposal phases). The approach should be at a level that considers broad classes of waste, rather than providing a focus on individual waste categories. High levels of confidence can be expressed for elements of the implementation plan in the relative short-term (e.g. where these reflect current operations or activities that are at an advanced state of preparation for implementation). Longer-term plans, such as final disposal of wastes to facilities that may not yet exist, are subject to greater levels of uncertainty and this should be recognised. An IWIP should be site specific but should consider and capture opportunities for shared resources and cross-site collaboration.

Where possible, the IWIP should identify Specific, Measurable, Achievable (or Attainable), Realistic and Time-bound (SMART) objectives related to waste management at the site. This can be a simple “signpost” to where such information already exists within current arrangements. The IWIP should contain a narrative clearly setting out the site’s waste management planning and should identify opportunities, risks, gaps (e.g. lack of characterisation data), uncertainties and any dependencies (e.g. wider UK strategic initiatives, availability of storage capacity or disposal facility).

Question 3

3. Process and use

Accepted Answer

The IWIP will inform NDA’s waste coordination process which seeks to involve relevant stakeholders and authorities to consider potential synergies and opportunities, and to identify risks so that these can be mitigated. Dialogue around the IWIP will give sites the opportunity to share challenges and ensure that their specific needs are properly discussed and prioritised across the NDA estate, and to enable information to be shared and opportunities for collaboration to be explored. By this process, sites will ensure that the NDA is fully aware of their future needs, which can aid the development of business cases. The IWIP will be used to appropriately inform NDA Strategy, and an update to align with and inform the next iteration of the NDA Strategy should be planned, see Monitoring and evaluating.

Additionally, it is intended that the IWIP will be co-ordinated with relevant technology developments at the site. Technological opportunities for improved waste management should be identified and considered as part of the implementation plan, if applicable.

The advantage to the NDA will be better coordination and management of waste across its estate by maximising opportunities to share resources and to provide a fuller overall picture of the state of waste management across its sites. This will provide the NDA with a greater understanding of future requirements, which in turn will enable the NDA to make better informed decisions. The clear identification of site SMART objectives will help demonstrate progress with the core mission of site clean-up. The IWIP process flow diagram is presented in Figure 2.

The following sections are intended to provide guidance on the structure and content of an IWIP and to encourage consistency.

Question 4

4. Implementing an Integrated Waste Strategy

Accepted Answer

4.1 Strategic aspects

A site-specific IWS should be aligned with the IWIP and, ideally, incorporated within it so that the site’s waste strategy and the plans to implement it are consistent and clear. The strategic elements should fundamentally align to, and be consistent with, the NDA Strategy, or should explain and justify any deviations from this, where applicable. At its core, an IWS should:

Be forward looking, outlining the overall mission, vision and the short-, medium- and long-term objectives for managing waste at the site in accordance with the Lifetime Plan (LTP);
Set out the objectives in such a way that both the aims and the reason(s) behind them are clear;
Set out how the NDA Strategy is being implemented, which should identify and explain any differences and/or deviations, where applicable;
Detail the SLC’s integrated and optimised approach to managing the full range of waste they generate; to achieve strategic goals (for waste, to complete mission);
Include a description of the outcomes of any strategic options study (or studies), RWMCs & disposability cases informing the IWS;
Recognise the key constraints and the impact these have on the shaping of the IWS; and,
Describe the general journey the site will take towards achieving its objectives, from “where we are” to “where we want to be”.

An account should be provided of the outcomes of any optioneering that has been undertaken in support of the site strategy development. This should demonstrate an optimised approach to managing the full range of waste. Optioneering guidance is provided by both the regulators and the nuclear industry, including: - the Environment Agency’s Regulatory Guidance Series^{[footnote 4]} - the joint guidance on the production of Radioactive Waste Management Cases^{[footnote 5]} - the nuclear industry code of practice on identifying and implementing ‘Best Available Techniques^{[footnote 6]}.

4.2 Interaction with other strategies, plans and deliverables

Figure 2 is essentially a high-level process flow diagram showing the interactions between policy, strategy and implementation planning. The value of this process will be in the flow of information to identify opportunities, enabling SLCs to actively influence the future NDA strategy development process. This flow of information will provide benefits to the NDA and stakeholders, as set out in the introduction. Notably, it will help enable the NDA to better forecast/predict the current and future needs of the estate and help to facilitate engagement with HMG and the Devolved Administrations, and may ultimately influence policy.

The site IWIP should identify innovative opportunities for managing waste that are set out in the site’s technology development programme, potentially utilising the Technology Baseline and Underpinning Research and Development documents (TBuRDs) and associated Technical Readiness Levels (TRLs) if applicable. This will reflect technologies that are conceptual (low technical readiness) and represent opportunities focussed on long-term goals, and more mature technologies (high technical readiness) that are anticipated for deployment in the near term or can be applied with high confidence at any stage during the mission.

The IWIP sits within an array of other strategies and documents. Figure 3 illustrates the typical interfaces and relationships and shows the thread from policy, through national strategy, to waste producer implementation. Notably, the IWIP may draw upon information that sits in other documentation and can signpost to this rather than recreating it. For example, in response to regulatory requirements^{[footnote 7]} sites are required to produce a Waste Management Plan (WMP) that is consistent with a Site-Wide Environmental Safety Case (SWESC). There may be useful elements of the WMP that can inform the IWIP, and vice versa.

Figure 3: Illustrative relationship of the IWIP to policy, strategy and implementation level documentation.

4.3 Implementation planning

The IWIP sets out how the site/operator implements an IWS aligned to the NDA Strategy and the site strategy through an executable plan. The IWIP needs to address how the strategy is to be delivered until the end of the NDA’s mission at the site. However, the focus of the plan should be on those types of wastes being managed actively at the tactical level through current operations and during the next few years, with longer-term elements of the plan identified as being of a more strategic nature and thus subject to greater uncertainty (such as those aspects contingent on the availability and timing of treatment, storage and disposal routes that are not currently available). The IWIP should facilitate a clear flow of information, thereby enabling the strategic and planning elements to influence each other.

The IWIP should make appropriate use of current arrangements and documentation and need only “signpost” existing documentation that provides relevant details (i.e. there is no expectation or requirement to produce vast new documentation where existing site arrangements can provide the necessary underpinning). The IWIP should be compact and include a concise narrative that identifies the current position and any future risks or opportunities. The level of detail should be such as to enable the NDA to measure the site’s progress in delivering the strategy, but most importantly should be capable of facilitating the early identification of site-specific and estate-wide opportunities, risks and any potential synergies.

At its core, the plan should:

Provide a description of the planned lifecycle management of each type of waste consistent with the IWS. One approach would be to show how plans align with the phases of the waste management lifecycle, inclusive of planning/optioneering, characterisation, retrieval, conditioning, storage, disposal stages. The use of illustrative charts/timelines/diagrams is encouraged, as is making use of existing documentation or arrangements that provide the underpinning detail;
Provide a narrative to accompany the identified activities within the plan in sufficient detail to describe the intent and any associated risks, opportunities and potential synergies;
Identify required infrastructure (e.g. waste conditioning plant, storage infrastructure, treatment routes etc.) and supporting regulatory permissions to enable utilisation;
Provide currently anticipated indicative timescales with any dependencies upon assumptions (e.g. presumed dates of Geological Disposal Facility (GDF) and/or other disposal route availability);
Reflect on the level of confidence/uncertainty regarding the delivery of the plan – greatest confidence in near-term (as per the Near-Term Work Plan (NTWP) and funding round), compared to longer-term elements, which are likely to be subject to much greater uncertainty;
The IWIP should identify required technological developments, where relevant, and consider the associated Technology Readiness Levels (TRL); and,
Where applicable (such as shorter-term goals), the above elements should be articulated and demonstrated using SMART objectives.

4.4 Assumptions

Any assumptions underpinning strategic aspects and implementation plans should be explicitly set out. Such assumptions could be categorised as generic (e.g. the date of GDF availability), or site specific (e.g. a specific store is designed and built with regulatory permission by a given date). Ideally information should be provided in tabular form.

Key dependencies should also be outlined (e.g. reliance on funding provision, plant throughput, national infrastructure availability, stakeholder & regulatory acceptance, technology availability and readiness etc.)

4.5 Risks, Uncertainties and Opportunities

A systematic compilation of risks, uncertainties and opportunities (including synergies and potential areas for collaboration across individual sites, SLCs & the NDA Group) should be provided. This should explicitly set out those key risks and uncertainties that are generic (e.g. disposal routes not available and hence longer-term storage required) and those that are more detailed and site specific (e.g. an assumed technology that has been identified for implementation as a waste treatment route at a site may not be mature enough by the proposed deployment date assumed in the plan).

Opportunities should be set out, particularly those identifying estate-wide dependencies/synergies and scope for collaboration with other sites (e.g. where the NDA estate would benefit from shared waste storage facility or waste treatment infrastructure, potential re-use of stores upon commencement of disposal etc.) Such opportunities should not be limited to those that are currently achievable, but should consider potential future possibilities as a goal to drive continuous improvement as outlined in the NDA Strategy (e.g. novel waste treatments or novel disposal options).

The NDA Strategy^{[footnote 1]} states that it, “…….is to make more use of a risk informed approach, rather than rely on the simple classification-based system for waste management and to seek solutions that help to optimise the lifecycle of both radioactive and non-radioactive wastes.” Each site’s IWIP document will need to demonstrate a risk informed approach. It should explain how waste risk management is conducted and it should describe how risks are linked to the delivery of specific waste management objectives and outcomes. The IWIP should indicate where a risk informed approach has affected waste management implementation at the site level, as well as where there are risks to the identified plan, e.g. lack of funding, achieving construction to an assumed timescale etc.

In order to maximise the value from NDA investments into R&D and innovation, the IWIP should cross-reference any identified waste management technology opportunities and consider these for incorporation into the IWIP. Technologies with lower TRLs or lead times beyond the life of the current IWIP should be identified as a potential future (but not scheduled) waste management option. This will assist the NDA in prioritising and funding their R&D and innovation programmes, as well as reporting where such programmes have benefitted site programmes.

It could be beneficial to consolidate and present all information responding to the assumptions and risks, uncertainties and opportunities in a succinct tabular form where possible.

To extract further value from site IWIPs, particularly in identifying risks, uncertainties and opportunities at both site and estate level, an IWM Topic Overview Group (TOG) meeting will provide an platform and forum with a specific IWIP focus. This will enable discussion of real-time risks and opportunities and ensure a flow of information between SLCs, the NDA and other TOG participants. Such information exchanges will inform a national IWM risks and opportunities register held/owned by NDA.

4.6 Communication and consultation

The production and presentation of the IWIP will be part of a wider communication and consultation process that will strengthen and improve communication between SLCs, the NDA, regulators and stakeholders on integrated waste matters. This will be further facilitated by information exchange at dedicated fora established by the NDA. This approach is integral to the NDA Strategy and consistent with the “One NDA” ways of working to maximise synergies and collaboration across the NDA group to help ensure effective and efficient delivery of the mission. The fora will be an opportunity to ensure awareness of plans and to discuss cross-site technologies, risks and programme opportunities, e.g. especially those that require significant future decisions, large initiatives, or sanction of timely funding.

The sharing and discussion of plans to incorporate technologies identified for development will enable other sites to potentially consider such opportunities for similar wastes, or for an agreed prototype testing schedule to be developed where one or more sites deliver and improve a technology before other sites incorporate that technology into their IWIP.

The IWIP also provides an opportunity for communication and consultation with the regulators. Ideally, this should commence at the earliest practicable stage of development of the IWIP to identify any key regulatory issues or concerns for specific sites and to minimise regulatory risk. Regulators should be made aware of the aims and objectives set out in the IWIP and the systems of integrated waste management which will deliver them.

The IWIP can be used to help ensure that decision makers and stakeholders are informed as plans develop to maturity and hence to avoid surprises. Production of an accessible IWIP summary, such as a poster or pamphlet aimed at non-technical audiences, would help inform internal and external stakeholders of the site’s waste management objectives and current progress against these. This could ensure transparency, improve stakeholder confidence and trust, and promote a collective awareness of site level plans towards NDA mission delivery.

Question 5

5. Monitoring and evaluation

Accepted Answer

5.1 Demonstrating Progress

Measuring progress in strategy implementation is an important aspect to enable NDA to demonstrate value for money. An IWIP will need to ensure that progress in implementing the plan is measurable using appropriate metrics (indicators), milestones aligned to specific implementation phases and overall a consideration of developing and utilising a high-level action plan. Examples could include the amount of waste conditioned versus a target for an operational plant, having optioneering outcomes in place to inform waste management decisions, achieving regulatory permissioning by a given date, and obtaining endorsements through the “Disposability Assessment Process”. SMART objectives should be identified where appropriate.

Where relevant site metrics currently exist, these should be clearly signposted in the IWIP together with an associated description to ensure clarity. The use of a dashboard-based approach would be welcomed if appropriately defined and supported by sufficient narrative to be understandable to an external audience.

5.2 Review Cycle

The IWIP should set out a timescale for review and update. All aspects of the strategy and implementation planning should be revisited on appropriate timescales, including the key objectives. Under routine circumstances a three-year review and update cycle should be considered for an IWIP, although detailed aspects of the implementation plan are likely to be “live” (Figure 4: Review cycles/periods.). Aspects of the implementation plan are likely to be subject to more frequent, routine change consistent with the delivery focus and vulnerability to factors such as plant availability and outages. Strategic aspects are unlikely to change as frequently. The IWIP will be considered annually in a dedicated NDA forum and this may prompt a limited annual review and update. As a minimum, an update should align with the NDA Strategy production process (a five-year cycle) and enable appropriate dialogue.

It is foreseeable that events (both internal and external) may render aspects of the strategy and implementation plans out of date. In the event of a major strategic change, a revision and realignment of the IWIP would be needed and SLCs may be required to progress revisions to align with changes to the NDA Strategy. An example of a major strategic change could be the adoption of near-surface disposal for selected HAW, as opposed to disposal in the GDF.

Timeline showing the review cycles/periods — Figure 4: Review cycles/periods.

Question 6

6. Glossary

Accepted Answer

IWIP (Integrated Waste Implementation Plan): Derived from the site IWS and provides more detail of how the IWS will be delivered and by when.
IWS (Integrated Waste Strategy): Describes how a site optimises its approach to the management of all waste arisings over the short-, medium- and long-term, up to site end state.
IWIP (+ IWS) Review Cycle: The cycle of full revision of the strategy and implementation plan. Coordinated with the NDA Strategy review period. Implementation plans are likely to be dynamic and hence to require more frequent updates than strategic level documentation.
LTP (Lifetime Plan): Often referred to as Site Lifetime Plan. Produced by the site as per NDA arrangements and revised annually. It gives details of the planned activities and costs of the work required to fully decommission the site to an agreed end state. The combination of all Lifetime Plans across the NDA estate yields the total cost of dealing with the NDA’s liabilities.
NDA (Nuclear Decommissioning Authority): A non-departmental public body of the Department for Business, Energy and Industrial Strategy, formed by the Energy Act 2004. It evolved from the Coal and Nuclear Liabilities Unit of the Department of Trade and Industry.
NTWP (Near Term Work Plan): Provides the scope of tasks, the plan schedule for completing the work and the costs associated with completing the tasks, for a rolling three-year period. It is a subset of the LTP and is underpinned by the detailed project plans. The NTWP ties to funding and scope guidance information provided by the NDA.
Plan: A detailed proposal for doing something, in this case achieving the objectives set out in the “strategy”. A “plan” is more detailed than a “strategy” but is generally shorter term defining who does what and when to achieve shorter term objectives consistent with meeting the overall mission and vision of the site.
RWMC (Radioactive Waste Management Case): The primary purpose of a RWMC is to provide a transparent demonstration of adequate radioactive waste management. The RWMC is described in joint regulatory guidance relating to the management of higher activity radioactive wastes (HAW) on nuclear licensed sites.
SLC (Site Licence Company): The term applied to operators of licensed nuclear installations.
The SLC holds the nuclear site licence, granted by the Office for Nuclear Regulation, to operate the nuclear site(s).
SMART (Specific, Measurable, Achievable (or Attainable), Realistic and Time-bound): Criteria to guide the setting of practicable goals and objectives.
SSS (Site Strategic Specifications): Define the required high-level outcomes based on the NDA Strategy so that there is a clear link between NDA Strategy and what is delivered by the SLCs
Strategy: Sets the overall mission and vision of the site and the general direction of the site to achieve these objectives. A “strategy” briefly identifies the route from “where we are” to “where we want to be”.
SWESC (Site-Wide Environmental Safety Case): This is defined in guidance issued by the environmental regulators. A documented set of claims, made by the operator of a nuclear site, to demonstrate achievement by the site as a whole of the required standard of environmental safety. Where relevant, the SWESC includes the environmental safety case for any on-site disposal facility. The SWESC also takes account of contributions to the combined impact on representative persons from adjacent nuclear sites, and from areas of contamination and previously permitted disposals outside the site.
SWOT (Strengths, Weaknesses, Opportunities and Threats): Criteria to aid analysis of strategic planning and strategic management.
TBuRD (Technology Baseline and Underpinning Research and Development): Documents produced at a site or SLC level in response to the NDA’s strategic objective to ensure that the delivery of NDA’s mission is technically underpinned by sufficient and appropriate R&D.
TRL (Technology Readiness Level): An approach to assessing technologies and their readiness for on-site deployment.
UKRWI (UK Radioactive Waste Inventory): Produced every three years and to provide the latest information on radioactive wastes and materials in the UK.
Waste Hierarchy: A relevant good practice framework for waste management decision making to enable an appropriate and effective balance of priorities, with a focus on waste prevention.
WMP (Waste Management Plan): This is defined in guidance issued by the environmental regulators. A documented plan, prepared by the operator of a nuclear site, which provides a comprehensive description of the current intent for dealing with all radioactive substances on or adjacent to the site and demonstrates how waste management has been optimised.

ENG04 Specification and guidance on the content and format of an Integrated Waste Implementation Plan

1. Preface