Stakeholder and Regulator Engagement Plan

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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
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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
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Circulation List
Name
Purpose of issue
Land Quality Technical Team
For review
Sellafield Ltd Communications Team
For review
Sellafield Ltd Document Security
For review
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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
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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
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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
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
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
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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
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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.
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This engagement is done via the
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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.
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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:
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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.
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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.
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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
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OCNS
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Sellafield Site Security
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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
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