The Nuclear Decommissioning Authority

Last Updated: 06 September 2010

Preventing the contamination of ground and groundwater is the first rule of protecting land quality; prevention is better than cure.  However, we recognise that leaks and spills do occur and have occurred in the past at NDA sites, leading to the contamination of ground or ground water with radioactive or non-radioactive substances existing in, on or under land at levels above the natural and artificial background levels typical of the area.  Therefore, the Land Quality Management (LQM) strategy will articulate the preferred strategy for managing this contamination to protect people and the environment, which includes protection of groundwater as a resource in its own right. 

LQM comprises actions to assess, characterise, control, monitor, remediate or remove contamination in, on or under land.

Objective

To ensure the optimum approach to safe LQM across the NDA estate.

Scope and Boundaries

The LQM strategy relates to the management of any contaminated ground or groundwater for which NDA or our Site Licence Companies are deemed responsible under relevant statutory provisions until the declared Site End State is reached and NDA's mission is complete.  The strategy considers management of radioactive and non-radioactive contamination once it is in the ground or groundwater until the material is determined and managed as waste (discussed in Integrated Waste Management strategies).  The first principle of LQM is to prevent contamination of ground and groundwater in the first place.  However, the actual activities required to prevent contamination of ground or groundwater, e.g. prevent leaks from facilities and manage gaseous or liquid discharges, are more appropriately covered in the strategy for Asset Management and for Low Level Waste (Liquid and Gaseous Discharges strand) respectively.

Within these boundaries, the LQM strategy needs to consider how land quality will be managed to protect people and the environment as well as the rate at which the Site End State will be achieved.

Interfaces

The LQM strategy interfaces with a number of other Topic Strategies in addition to the majority of the enabling strategies.  The most notable interfaces are:          

• Site End States Strategy is relevant because the proposed Site End State defines the land quality that must ultimately be achieved.
• Decommissioning and Clean-up Strategy is relevant because site restoration strategies must be consistent.  For example, the relative timing of decommissioning and clean-up activities may impact requirements for control and monitoring of land contamination, and may risk (re)contaminating land.
• Integrated Waste Management topics are relevant because the waste management hierarchy influences the approach to LQM.  Also, a robust understanding of the proportion of ground and groundwater that could be excavated and sentenced as waste will inform the development of national solutions and the infrastructure required for waste management; vice versa, plans for managing land quality are influenced by national solutions for waste management and the availability of waste routes.

Credible Options

The credible options for managing land quality to protect people and the environment are:

1.      Manage contamination in-situ via Monitored Natural Attenuation

2.      Manage contamination in-situ via active control or remediation

3.      Manage contamination ex-situ to allow excavated material to be reused / recycled

4.      Manage contamination ex-situ as waste in accordance with the appropriate waste management strategy and regulatory framework.

The credible options for the rate at which the Site End State is achieved are:

1.      Accelerate land quality management to achieve the Site End State as quickly as possible

2.      Manage land quality to achieve the Site End State at a rate that represents lowest short-term cost

3.      Manage land quality to achieve the Site End State at a rate that represents greatest overall value to the UK taxpayer

All of the above credible options are dependent on the land being characterised adequately so that the consequences of implementing a specific option are understood.

Current Position

The 2006 NDA Strategy guides Site Licence Companies to:         

• accelerate characterisation of land;
• develop fully costed and robust long-term management plans;
• create and maintain appropriate records; and,
• monitor contamination whilst plans are being developed.

The 2006 Strategy also references the role of the Regulators who will subject plans to independent scrutiny and exercise powers as necessary to protect people and the environment.

The 2006 NDA Strategy is being implemented; all SLCs have an improved conceptual model of land quality and have developed or are developing land quality management plans.

Based on our improved understanding of land quality at NDA sites, it is evident that the volume of land estimated to be or have potential to be radioactively contaminated exceeds the Low Level Waste (LLW) disposal capacity available nationally at present.  As such sentencing and managing all this land as waste (radioactive or non-radioactive) would be a considerable challenge, and represents a significant risk to the proposed UK Nuclear Industry LLW strategy that is out for consultation at the time of writing.  The waste management hierarchy is at the heart of the LLW strategy, and flows through to the management of land quality.

Site Lifetime Plans predict that the management of land quality will cost a total of £3.6 billion, excluding the cost of managing excavated material as waste.  This is a significant proportion of the total Nuclear Liability Estimate and we have a responsibility to ensure that this cost is justified.

The optimum approach to managing land quality (preferred option) is case-specific (specific to the nature and extent of the contamination, as well as the site setting), which limits how directive NDA Strategy can be. We have developed a view of successful LQM aligned to the credible options that will inform case-specific decisions being made by Site Licence Companies.

To mitigate strategic risks, LQM will protect people and the environment in a manner that makes best use of available resources, including appropriate application of the waste management hierarchy.