Land Quality 05/08/2013 LQTD000065 Land Quality Stakeholder & Regulator Engagement Site Remediation & Decommissioning LQTD000065 Role Author Land Quality Technical Support Checker(s) Technical Manager Land Quality Approver Technical Lead Land Quality Document Number: LQTD000065 Signature Date Page 1 of 16 Land Quality 05/08/2013 LQTD000065 History Sheet Rev Date Reason for revision Revised by 01/09/2011 Draft for comment Land Quality GIS Support 1 10/10/2011 Revision 1 Land Quality GIS Support 2 05/08/2013 Revision 2 Land Quality Technical Support Document Number: LQTD000065 Page 2 of 16 Land Quality 05/08/2013 LQTD000065 Circulation List Name Purpose of issue Land Quality Technical Team For review Sellafield Ltd Communications Team For review Sellafield Ltd Document Security For review Document Number: LQTD000065 Page 3 of 16 Land Quality 05/08/2013 LQTD000065 Contents Item Page History Sheet 2 Circulation List 3 Contents 4 Abbreviations 5 Introduction 6 Scope 6 Background 6 Land Quality Engagement Progress (Since 2006) 7 Stakeholders 9 Regulators 10 Implementation 11 Index of Stakeholders 13 References 15 Document Number: LQTD000065 Page 4 of 16 Land Quality 20/01/2012 LQTD000065 Abbreviations EA Environment Agency EMA Environmental Monitoring & Assessment LQPRP Land Quality Peer Review Panel LQTRG Land Quality Technical Review Group LTP Life Time Plan NIGLQ Nuclear Industry Group for Land Quality ONR Office for Nuclear Regulation ONR - CNS Office for Nuclear Regulation - Civil Nuclear Security RTS Regulator Tracking System SAGTA Soil and Groundwater Technology Association SAFEGROUNDS Safety and Environmental Guidance for the Remediation of Contaminated Land on UK Nuclear and Defence Sites SCL&GMP Sellafield Contaminated Land & Groundwater Management Project SLM Sellafield Ltd Manual SLP Sellafield Ltd Practice SLSP Sellafield Ltd Supporting Practice SR&DP Site Remediation and Decommissioning Projects WCSSG West Cumbria Site Stakeholder Group Document Number: LQTD000065 Page 5 of 16 Land Quality 20/01/2012 LQTD000065 Introduction The ‘Land Quality Stakeholder and Regulator Engagement’ document is intended to detail stakeholder and Regulator interactions undertaken by The Land Quality department throughout the course of dayto-day operations and project work. The Land Quality department has a number of interactions both internal and external to Sellafield Ltd. Scope This document covers the stakeholder and Regulator interfaces generated by activities associated with the management of contaminated land and groundwater at Sellafield site. These activities are captured in the Sellafield Life Time Plan (LTP) and locally in annually produced Task Plans. All interactions with stakeholders external to Sellafield site adhere to the Sellafield Ltd Management System document ‘How do I engage with external stakeholders?’ SLP 4.08.01. The requirement for individual projects to produce a bespoke Stakeholder Engagement Plan will be determined when the project task plan is approved at LQTRG. The intention is to review this document on a three year basis. Background There has been an industrial site located in the Sellafield area for over 60 years and as such there is a legacy of contaminated land and groundwater under the site. The present Land Quality team was formed in 2006 and since this time the team has aimed to improve communication and provide timely and relevant information to stakeholders, both internal and external, in line with Sellafield Ltd requirements to “understand, control and manage the legacy of ground contamination to ensure protection of the workforce, the public and the environment” (Sellafield Ltd, 2013: Land Quality Management at Sellafield – Home). During an initial stakeholder analysis session conducted in 2006, the following groups were identified and prioritised depending on their impact to Land Quality activities, and these groups remain unchanged: Sellafield Site (impacted plants, projects and committees) Regulators Document Number: LQTD000065 Page 6 of 16 Land Quality 20/01/2012 LQTD000065 External Stakeholders Land Quality Engagement Progress (Since 2006) Programme of BAT Studies A programme of BAT studies has been initiated, with the Windscale Trenches BAT study taking place in 2012. The outcome of the study is currently being developed into a work scope and is progressing through the site governance processes. The scope of the current BAT study is the contaminated groundwater in the saturated zone beneath the Sellafield site, and is due for completion by 2014. Once the groundwater plume BAT study is complete, the programme will continue to work through the source terms identified in the current conceptual model. Sellafield Contaminated Land & Groundwater Management Project (SCL&GMP) 2010 saw the completion of SCL&GMP to improve the characterisation of the subsurface beneath Separation Area by installing a series of groundwater monitoring wells. The operations phase was completed in July 2009 when the drilling rigs were demobilised. The final round of sampling was completed in November 2009 and The Land Quality department took receipt of the Conceptual Model Report (first draft) in March 2010. The delivery of the Conceptual Model Report was a Directorate Milestone and the final suite of documents were delivered in August 2010. Best Practice & Standards Conferences and Inter-industry Groups such as; Brownfield Briefing, CIRIA, CLAIRE, Consoil, meetings with Cumbria County Council, NEOACD, SAFEGROUNDS, SAGTA, and NIGLQ are regularly attended by The Land Quality department. Site visits to Hanford, Washington, Grand Junction, Colorado, Avenue Coking, Chesterfield, Dungeness, Chapelcross and Dounreay have allowed the exchange of information and best practice. The Land Quality department have also engaged the LQPRP resource to review key outputs. It is important for technical teams to be kept informed on industry developments, best practice and standards. In response to this the Land Quality department have formed a Centre of Expertise for contaminated land and groundwater monitoring, and are part of the Centre of Expertise for mathematics and statistics. Contaminated Land Visualisation Document Number: LQTD000065 Page 7 of 16 Land Quality 20/01/2012 LQTD000065 Progress has been made in improving the capability to visualise data, in terms of expertise, man-power, software and resource. Currently The Land Quality department are reviewing models developed during SCL&GMP in order to provide updates to the Conceptual Model and Risk Assessment Reports. This will ultimately allow The Land Quality department to improve decision making. Land Quality Data Management System A project to setup a data management application that would incorporate all relevant Land Quality data is currently underway. The completion of this work will lead to a step change in Land Quality data management practices, it will provide a robust and clean audit trail for all data which will give greater confidence and transparency. Ultimately this application will allow better provision of data for Operating Units on site, and assist with source term specific BAT studies. Strategy & Planning The Land Quality Strategy (Teasdale, 2013) was approved by the Decommissioning Strategy Review Group in 2013, and will be made available via the Land Quality web page. This strategy aligns with the site and NDA strategy documents and outlines the general direction of the Land Quality team in the medium term. Groundwater Monitoring Following the installation of the SCL&GMP groundwater monitoring wells, the Groundwater Manager conducted a review of the Groundwater Strategy. This review looked at the statutory programme, the Regulatory requirements and expectations, and resource in terms of groundwater monitoring wells and sampling team capability. The outcome is a revised statutory programme that meets requirements of the Environmental Permits in an efficient manner as well as providing an increased understanding of groundwater contamination and transport processes. This programme is scheduled for review in 2014. Source & Pathway Investigations A number of projects have been undertaken to improve the characterisation of the subsurface, for example the Windscale Trenches and the Beach Springs. Further opportunistic investigations have Document Number: LQTD000065 Page 8 of 16 Land Quality 20/01/2012 LQTD000065 arisen and The Land Quality department has taken the initiative and extended their knowledge and expertise of contaminated land on site. University Engagement The Land Quality department has a number of on-going collaborations with universities to address knowledge gaps and develop potential new technological solutions. The recent focus has been in three main areas, development of potential new sampling methodologies at the University of Lancaster; development of biomineralisation methodologies at the University of Manchester; and assessment of radionuclides transport into beach springs at the University of Birmingham. The Land Quality department have also developed a close working relationship with the Nuclear Waste Research Forum as a member of the Land Quality Sub-Group and with the National Nuclear Laboratory who manage much of the NDA funded academic research. Stakeholders Sellafield Site (impacted plants, projects and committees) Interactions between Operating Units, Projects and Land Quality are controlled by the Contaminated Land Manager, Groundwater Manager and Land Quality Technical Team. These roles are supported by the following Sellafield Ltd Management documentation: Contaminated Land Safety Case Contaminated Land and Groundwater Manual (SLM 1.07.04) How do I Accumulate Activity in the Ground at Sellafield (SLP 1.07.42) How do I ensure compliance with Contaminated Land Requirements During Excavation Work at Sellafield (SLP 1.07.41) How do I Manage Excavations (SLP 2.04.211) How does the Contaminated Land Manager Support Projects Accumulating Activity in the Ground at Sellafield (SLSP 1.07.42) Conversely, work carried out by the Land Quality department, the sampling teams and associated contractors, potentially impacts many areas of site. In general work is non-intrusive and routine, however engaging with Operating Units and Projects early and on a regular basis ensures the flow of communication is maintained and that no works are delayed. Document Number: LQTD000065 This engagement is done via the Page 9 of 16 Land Quality 20/01/2012 LQTD000065 Integrated Works Management process which is being implemented across the Sellafield site, the Tactical Land Group and the Strategic Land Authority. During work-planning the Land Quality department will identify affected Operating Units and Projects and develop an understanding of their requirements and the impact Land Quality activities will have. Contacts will be identified from within each affected Operating Unit or Project to ensure that the Land Quality department supply information in a clear and consistent way. The relevant committees will be informed of impacts to site infrastructure, these include but are not limited to; the Roads Committee, Site Outage Committee, Siting Committee and Departmental Safety Forums. The Land Quality department also acts in a supporting role and advisory capacity to many of the larger facilities on site and maintain a dialogue with their associated Operating Unit or Projects day-to-day. A member of the Land Quality team attends the SR&DP Management Safety Committee to provide comments from the Land Quality department, and quarterly liaison meetings are held with EMA to ensure environmental protection strategies are integrated across the departments. The Land Quality team also engage in integrated waste strategy meetings and are part of the radioactive waste inventory group. The Land Quality department also interacts with the site Security teams, using the management system document; SLM 2.01.01. Finally, Sellafield site employees will be kept informed of Land Quality activities through existing internal communication channels. External Stakeholders It is recognised that the activities of The Land Quality department will be of interest to many external stakeholders. Therefore it is important that these stakeholders are kept informed and that appropriate documentation on the key issues is provided. Where appropriate, external stakeholder engagement will be coordinated in association with other groups to take advantage of established communication networks, for example the West Cumbria Sites Stakeholder Group (WCSSG). The Land Quality department’s principal public communication tools are the Groundwater Annual Report and the Land Quality website. The Groundwater Annual Report is delivered every September to the Environment Agency and Office for Nuclear Regulation for review prior to public distribution. The Land Quality website is updated in line with the Groundwater Annual Report and on an ad-hoc basis as and when required. Document Number: LQTD000065 Page 10 of 16 Land Quality 20/01/2012 LQTD000065 All interactions with external stakeholders are governed by the Sellafield Ltd Management System document ‘How do I engage with external stakeholders’ SLP 4.08.01. As stated in the ‘Scope’ of this document, individual projects will produce bespoke Stakeholder Engagement Plans when necessary, therefore any external stakeholder engagement relating to an individual project will be managed using SLP 4.08.01 as and when the need arises. Regulators Interactions with Regulators are managed using SLSP 4.07.05 ‘Regulator Engagement Process, Guidance and Responsibilities (Decommissioning Directorate)’. The Land Quality department engages the Office for Nuclear Regulation (ONR) and Environment Agency (EA) via; 1. SR&DP Programme Stakeholder Meeting. 2. Groundwater Technical Meetings for Land Quality. 3. Regular correspondence on concerns and milestones. 4. Correspondence on ad-hoc activities and events. The NDA are present at the SR&DP Programme Stakeholder Meeting. Where The Land Quality department’s activities have an impact on site security arrangements, interface with the Office for Nuclear Regulation – Civil Nuclear Security (ONR - CNS) will be required and coordinated through Sellafield Ltd Security. Implementation Stakeholder and Regulatory Engagement is a constant feature of programme management, and as discussed the team strives to meet the demands of both internal and external stakeholders as well as Regulators. The Land Quality website is used to release documentation to the public and The Land Quality department participate in external meetings in order to keep the public informed of activities. Individual projects may go further and consult, involve and collaborate with the public in final decision making. The programme predominantly relies on the following tools: Document Number: LQTD000065 Page 11 of 16 Land Quality 20/01/2012 LQTD000065 Internal Communication Tools Method of Implementation Operating Unit Technical Memos 1. Technical Memos are produced regularly to brief OU’s on the groundwater conditions in the vicinity of their plant. 2. Authoring is undertaken by the Land Quality Technical Team. Information Requests 1. Data requests may come form any project, Operating Unit, team or individual on site. 2. The Land Quality department reviews the request and assigns an owner to respond. 3. All information is reviewed prior to sending and all enquires are logged for future reference using the ‘Technical Information Request Log’ (Ross, 2011). Ad-hoc Support for Events 1. Ad-hoc support for events is work that is not programmed into The Land Quality department’s task plans for the year. 2. The Land Quality Technical Team support investigations via sampling, analysis and technical expertise. Sellafield Ltd Management System Processes 1. The Land Quality department has produced a suite of documentation that details Land Quality processes, interactions, guidance etc. These documents are under continuous review to ensure they reflect current practises. 2. The Land Quality department are already in line with site-wide processes, interactions, guidance etc. where applicable. Committee Membership 1. The Land Quality department has membership on relevant committees where the team affect or are affected by other Projects and OU operations on site, such as the SR&DP Management Safety Committee and SR&DP Event Peer Review Committee. Document Number: LQTD000065 Page 12 of 16 Land Quality 20/01/2012 LQTD000065 External Communication Tools Method of Implementation Groundwater Annual Report 1. The production of the report is led by the Groundwater Manager. 2. The report is authored by multiple members of the Land Quality Team. 3. Delivery of the report to EA and ONR takes place every September as an agreed milestone. 4. The findings of the report are presented to the WCSSG in the November meeting. 5. The report is released to the public via the Land Quality Website. Land Quality Website 1. The Land Quality Website is updated alongside the production of the Groundwater Annual Report. 2. The contents are reviewed internally by the Land Quality team, Document Security, Intellectual Property, Commercial and Communications prior to release. 3. Where required it is also updated on an ad-hoc basis. Regulatory Communication Tools Method of Implementation Regulatory Correspondence 1. Routine correspondence on Regulatory issues. 2. Ad-hoc correspondence on events and issues. Regulatory Meetings 3. SR&DP Programme Stakeholder meetings are organised centrally by SR&DP. 4. Groundwater Technical Meetings are organised locally by The Land Quality department. 5. All correspondence is coordinated by a designated member of The Land Quality department and logged on the RTS. Index of Stakeholders Below is a list of Stakeholders that The Land Quality department have considered, it is not exclusive and may be amended as and when required. Document Number: LQTD000065 Page 13 of 16 Land Quality 20/01/2012 LQTD000065 STAKEHOLDER STAKEHOLDER CONTACT Internal Stakeholders Projects and Operating Refer to Organisational Charts and site address book for contacts. Units Refer to Project Notices for contacts. Off Site Environmental Refer to Organisation Charts and site address book for the contact details of the Issues current role holder. Resident Engineer Refer to Organisation Charts and site address book for the contact details of the current role holder. Strategic Land Authority Refer to Organisation Charts and site address book for the contact details of the current role holder. Land Access & Refer to Organisation Charts and site address book for the contact details of the Infrastructure Committee current role holder. Trade Unions Contact Facility Characterisation Union Representative. External Stakeholders Public Refer to SLP 4.08.01 WCSSG Refer to Environmental Management & Assessment (EMA) for contact details of WCSSG secretary. Customer NDA Land Quality Regulator Liaison STAKEHOLDER STAKEHOLDER CONTACT Regulators EA Land Quality Regulator Liaison ONR Land Quality Regulator Liaison Document Number: LQTD000065 Page 14 of 16 Land Quality 20/01/2012 LQTD000065 OCNS Document Number: LQTD000065 Sellafield Site Security Page 15 of 16 Land Quality 20/01/2012 LQTD000065 References NDA. 2011. Strategy (Effective from April 2011). Nuclear Decommissioning Authority. ISBN 978-1905985-26-5. Available online from http://www.nda.gov.uk/documents/upload/NDA-Strategy-Effectivefrom-April-2011-full-colour-version.pdf [Accessed 01/11/2011] McKenzie, H. M., Coughlin, D. P., Stamper, A. L., and Laws, F. Groundwater Annual Report 2011. TECH001072. Available online from http://www.sellafieldsites.com/land/pages/document-library.html [Accessed 13/06/2013]. Ross, M. O. 2011. Land Quality Technical Information Request Log Process LQ/ADH/GD/03-2 Sellafield Ltd. Land Quality Management at Sellafield. Available online from http://www.sellafieldsites.com/land/ [Accessed 13/06/2013]. Teasdale, I. 2013. Land Quality Strategy MAN000694 Document Number: LQTD000065 Page 16 of 16