The Office for Nuclear Regulation (ONR), an agency of the Health and Safety Executive (HSE), has completed a review of the strategy for nuclear decommissioning on the site licensed to BAE Systems Marine Limited (BAESM) in Barrow-in-Furness. In completing the review, the ONR consulted both the Environment Agency (EA) and the MoD's Defence Nuclear Safety Regulator (DNSR). The review discharged the duty on HSE, contained in the decommissioning section of Cm2919 that was updated in September 2004, to review on at least a five-yearly basis the strategy for cleanup of each UK site that is licensed under the Nuclear Installations Act 1965 (as amended) (NIA65).
Our review firstly considered the appropriateness of BAESM's current strategy in the context of key findings from the previous Quinquennial Review (QQR), which was published in 2004. We also sought evidence to demonstrate that BAESM had put in place arrangements to ensure its decommissioning strategy was kept up-to-date in response to such changes.
Significant changes have taken place in government policy towards nuclear decommissioning, management of radioactive wastes and the country's defence capability in the last 5 years. Amidst these changes, the most important for nuclear decommissioning at BAESM were to government policy for decommissioning and the long-term management of Low Level Waste (LLW) and Very Low Level Waste (VLLW). In addition, HSE issued new guidance on the criteria it will use for de-licensing of nuclear sites (the so-called No Danger criterion) in 2005 and revised its Safety Assessment Principles (SAPs) in 2006.
BAESM made a submission to inform the regulatory review the HSE, EA and DNSR considered this alongside other data and concluded that overall, BAESM's decommissioning strategy was appropriate. Since the last QQR, BAESM has decommissioned its historic shore-based effluent treatment facilities and replaced them with new plant to support the construction of the Astute class submarines, disposed of a legacy of radioactive wastes and engaged proactively with local stakeholders. Decommissioning of the Nuclear Facilities Barge (NFB) which commenced during the course of the review provided a useful demonstration of BAESM's competence in achieving decommissioning and applying the waste hierarchy as required by its arrangements.
The licensed site at Barrow features a relatively small number of facilities that are affected by very low levels of radioactive contamination (a radiochemical laboratory, Waste Treatment Facility, redundant foundation slab in the DTO Car Park, and possibly an underground tank and pipe-work in the vicinity of the laboratory). It follows that the technical challenges, radiological hazards and financial liabilities associated with achieving decommissioning at BAESM are very much lower than seen elsewhere. The widespread availability of methods to achieve this type of cleanup and the competence that BAESM has demonstrated in its decommissioning of the NFB gives a very high degree of regulatory confidence that BAESM's strategy is deliverable.
The low-level nature of the radiological hazards found at Barrow implies any deferral to decommissioning would not bring any significant benefits in terms of safety nor environmental protection. As such, the regulators support BAESM's proposed approach of carrying out decommissioning promptly once its plant is declared redundant. The timing of decommissioning at Barrow is also by necessity dependent on the UK submarine programme and is therefore subject to the strategic decisions of the UK government. Current government policy indicates that the Barrow Licensed Site will be used to construct all the Astute class submarines and will continue to play a role in the construction of nuclear submarines for the foreseeable future. De-licensing of the site is therefore unlikely to take place for a considerable number of years. The existing plant is of modern vintage and unlikely to be declared redundant in the near future. For the purposes of safety and environmental protection, it is acceptable for BAESM to rely on a high-level decommissioning strategy at this point in time. Supporting studies should be relatively simple to prepare and it is highly likely that the external constraints that need to be taken into account in such studies (such as waste categorisations) will be subject to change before the time comes for the decommissioning to be carried out.
When decommissioning progresses, it will be important for BAESM to demonstrate that its LC35 compliance arrangements remain aligned with the MoD's developing approach. This may require BAESM to reformat or further supplement the data that was submitted for this review. We are keen for BAESM to liaise closely with the MoD to ensure that all decommissioning work at Barrow is appropriately recognised in the MoD's strategy, plans and provisions.
In order to avoid the imposition of an unnecessary regulatory burden, UK government policy supports the completion of QQRs except where alternative and equivalent arrangements are in place for other purposes (such as liabilities accounting). With this in mind, the regulators have concluded that, in the case of the Barrow Licensed Site, the QQR process has provided a useful focus for both the regulators and the operator to ensure that BAESM's decommissioning strategy remains fit-for-purpose. ONR intends to play a proactive role in MoD's development of its overarching liabilities management strategy and will take account of developments with that initiative in the decision on whether a further QQR will be necessary in 2014.
This review has identified that BAESM needs to undertake timely remediation of the redundant foundation slab in the DTO Car Park and establish the status of a redundant underground tank and associated pipe-work local to the laboratory. BAESM should update its entry in the National Waste Inventory in order to ensure that the MoD, the NDA, the operators of the LLWR and other third parties are properly aware of the waste types and volumes that exist at BAESM as these organisations are responsible for ongoing developments in national level plans and policies that will have an impact on future decommissioning work at BAESM. BAESM should also protect its intelligent customer capability for waste management and decommissioning by ensuring this competence is recognised in its staffing baseline.
In order to obtain the Assessment Report that has informed the above statement, contact ONREnquiries@onr.gov.uk quoting the following:
Summary Website Statement: TRIM Record 2010/306740
Assessment Report: TRIM Record 2010/306671
Chief Inspector of Nuclear Installations
Office for Nuclear Regulation