doc no eng 01 rev 3 eng01 - specification and guidance on ... · specification and guidance on the...

Specification and Guidance on the

Content and Format of an Integrated

Waste Strategy

Doc No ENG 01

Rev 3 19 Oct 2012

This document has uncontrolled status when printed of 21 Rev 3

ENG01 - Specification and Guidance on the Content and

Format of an Integrated Waste Strategy

Revision 3



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PREFACE .....................................................................................................................................................................3

GLOSSARY ..................................................................................................................................................................6

1 INTRODUCTION..................................................................................................................................................7

2 COMMUNICATION AND CONSULTATION ........................................................................................................9 2.1 Regulatory input and consultation.................................................................................................................9 2.2 Stakeholder input and consultation...............................................................................................................9 2.3 Accessibility.................................................................................................................................................10

3 OBJECTIVES AND AIMS...................................................................................................................................11 3.1 Where Are We? Where Are We Going? ...................................................................................................11 3.2 Setting Objectives .......................................................................................................................................11 3.3 The Waste Hierarchy ..................................................................................................................................12 3.4 Interaction with other strategies and plans .................................................................................................13

4 DATA GATHERING ...........................................................................................................................................15 4.1 What Wastes Do We Generate At Present? ..............................................................................................15 4.2 What Wastes Will We Generate In The Strategy Period?..........................................................................15

5 CRITICAL EVALUATION OF WASTE MANAGEMENT OPTIONS...................................................................16 5.1 What Do We Do At Present?......................................................................................................................16 5.2 What Will Be Needed In The Future?.........................................................................................................16 5.3 Are existing routes and plans satisfactory? ................................................................................................16

6 HORIZON...........................................................................................................................................................18 6.1 Key Deliverables, Decisions and Required Timescales for Delivery ..........................................................18 6.2 Risk and Opportunity Management in Strategy Delivery ............................................................................18 6.3 Action Planning ...........................................................................................................................................18

7 MONITORING AND EVALUATION ...................................................................................................................20 7.1 IWS review cycle.........................................................................................................................................20 7.2 Indicators and metrics.................................................................................................................................21 7.3 Reporting and audit.....................................................................................................................................21



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PREFACE This document is the Specification and Guidance produced by the Nuclear Decommissioning Authority (NDA) to Site Licence Companies (SLC) on developing an Integrated Waste Strategy (IWS). The guidance is also of relevance to non-NDA waste producers in the nuclear industry, as there is value in the whole nuclear industry adopting the same approach to waste strategy development. This issue replaces the earlier IWS specification (ENG01 Revision 2) and its companion document (ENG02) issued in August 2006. The basis for a requirement to deliver an IWS has evolved since the initial guidance was published, and this version reflects these changes whilst attempting to improve the effectiveness and consistency of IWS across waste practitioners, both in production and in implementation. This issue also reflects stakeholder views and experiences regarding what an IWS should achieve. In particular, these were explored in a major stakeholder workshop, the ‘National Integrated Waste Strategy Shaping Event’ held in January 2011 and reported by the Office of Nuclear Regulation 1. This revision draws on the findings of the stakeholder event and subsequent consultations, which conclude: • an IWS should be concise, strategic and a communication tool, with a focus on how wastes will be

managed now and over the site lifetime; • an IWS should set out what challenges lie ahead and when they need to be addressed; • the IWS specification needs to define the relationship with other radioactive and non-active waste

products; • the specification could usefully set out the expectations of regulators and how an IWS will be

assessed by them; and • the specification should signpost rather than duplicate management procedures set out in other

documentation. This revision is intentionally less prescriptive than the earlier version. Instead, the guidance builds on first principles, considering what a strategic document should be and what it should include. In structure it draws on national guidance on developing Municipal Waste Management Strategies, which has helped several hundred local authorities to deliver useful and deliverable strategies. Whilst the nature of waste arisings in the nuclear industry differs in some respects (especially for radioactive waste), the principles of waste management and the significance of the waste hierarchy hold true for all waste producers and waste types.

1 - http://www.hse.gov.uk/nuclear/iws-shaping-feedback.pdf



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This guidance is intended to ensure that an IWS is a useful internal document and communication tool for helping to take forward waste management issues. Principally it seeks to answer three key questions: • Where are we today? • Where do we want to get to and when? • What actions are needed to get there? An IWS should therefore summarise the direction of travel and the key milestones that will occur within the short, medium and longer time periods, up to site end state. By necessity it sits within a complex map of other strategies and documents. The relationship between the IWS and waste inventory (both site and UK Radioactive Waste Inventory) is of particular importance because the inventory sets out the scope of radioactive waste to be managed. The interface between the IWS and the site lifetime plan is also important because the plan will set out the detailed actions for managing waste and therefore implementing the strategy. The TBURD2 will address technical challenges identified in the IWS development and the operator should also maintain an IWS Action Plan to address other requirements of the IWS and demonstrate progress in the development of IWS. The IWS document should provide a clear picture to internal and external stakeholders of those documents rather than duplicating them in scope and purpose. Moreover, the IWS must remain relevant to the activities occurring on site. As such, it should be reviewed on period of no more than three years or when circumstances change, as described in this guidance. Ultimately, the purpose of this revised guidance is to aid and encourage more strategic and forward-looking strategies to be developed which are integrated across all waste streams. NDA looks forward to working with stakeholders in moving towards this aim.

2 - Technical Baseline and Underpinning Research and Development document



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Success Criteria A successful Integrated Waste Strategy will: • Lead to better, more integrated, waste management • This should be based on an effective and defensible balance of priorities • The strategy will ensure direction on waste management throughout the business – from Director

level to operators on the ground • It should ensure the confidence of Regulators and interested parties in how waste is managed by n

organisation and / or site. A successful IWS document will: • Clearly identify what wastes need to be manage (both radioactive and non-radioactive) • Describe how they are managed now and in the future, taking account of the full waste lifecycle • Demonstrate how the strategy is delivering against national policy and strategy • Sign post to key underpinning and justification information in an effective and accessible way

(including UK Radioactive Waste Inventory, TBURDs, etc) • Identify future problems and/or gaps, and the solutions to address them • Drive improvement by focusing on key outcomes • Show how the strategy will be implemented and how it factors into business decisions • Be an integral part of meeting regulatory requirements for waste management • Be available and accessible to people Acknowledgements NDA wish to acknowledge the constructive contributions made by regulators, SLCs and other stakeholders during the development of this guidance document, including the participants in the National Integrated Waste Strategy Shaping Event held in January 2011. NDA also acknowledges the support of Environmental Resources Management Ltd (ERM) and Integrated Decision Management Ltd (IDM) in preparing this guidance.



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GLOSSARY

Term Definition

Action plan Action plans track the actions to be delivered as part of IWS, who they are to be actioned by, when and whether they have been completed.

Action plan review cycle A process for the regular review of Action Plans should be established, with reviews occurring at least once every 12 months or sooner at significant events or occurrences.

IWS Integrated Waste Strategy which describes how a site optimises its approach to the management of all waste arisings over short, medium and long term, up to site end state.

IWS period For NDA sites is equivalent to the timescale covered by the Site Lifetime Plan. For non-NDA sites an appropriate and representative timescale could be established, with input from stakeholders.

IWS review cycle The cycle of full revision of the strategy. This period is flexible, however should be no longer than three years.

LTP Site Lifetime Plan.

NDA Nuclear Decommissioning Authority.

SLC Site Licence Company(ies).

TBuRD Technical Baseline and Underpinning Research and Development (baselines established to allow the delivery of systematic and progressive reduction of all hazards associated with a nuclear facility)

Waste Hierarchy A framework for waste management decision making to enable an effective balance of priorities, with a focus on waste prevention.



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1 INTRODUCTION This document is Guidance produced by the Nuclear Decommissioning Authority (NDA) to Site Licence Companies (SLC) on developing an Integrated Waste Strategy (IWS). The guidance is also of relevance to non-NDA waste producers in the nuclear industry. It is the view of regulators and stakeholders that a consistent approach to waste strategy development is beneficial for all interested parties. An IWS is a strategy that describes: • how a waste producer optimises its approach to waste management in an integrated way; • the waste streams and discharges expected from current and future operations; and • actions required to improve the approach to waste management. This document sets out the key activities required to develop an integrated waste strategy and also provides guidance on how that strategy should be described in an IWS document. The exact content and style of the IWS will be specific to the waste producer; however, the structure of this document is intended to provide a template for IWS documents to encourage a certain level of consistency. A waste producer’s integrated waste strategy includes all radioactive and non radioactive wastes (solid, liquid and gaseous) arising from past, present and future operations, including waste transferred from other organisations for management or disposal. Developing and maintaining an IWS has the following benefits: • It ensures internal and external stakeholders are aware of waste management plans going forward • It demonstrates capability and capacity to manage all waste arisings or will identify gaps and the

actions needed to address them • Risks and opportunities will be identified and actions put in place to mitigate or realise them

respectively. • It will ensure waste management activities are optimised and interface effectively with other

activities on site, for example, operations, decommissioning and site restoration. • It will meet the requirements of UK policy for the management of solid LLW waste, which requires

operators to have plans for the management of their waste (see paragraphs 7 & 8 of the UK LLW policy statement3).

• It supports lifetime planning for sites. Production of an IWS may be appropriate at the site level, management company level or even at higher levels. It is important to discuss with stakeholders what is an appropriate level at which to deliver an IWS: some will be interested at the management company level, others may be more interested at the site level. This guidance is intended to direct authors across all levels in producing an IWS.

3 - Policy for the Long Term Management of Solid Low Level Radioactive Waste in the United Kingdom



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NDA Site Licence Companies already produce IWSs. However, the guidance developed to assist their production (ENG01 and ENG02) is now six years old and the basis for a requirement to deliver an IWS has evolved. This version reflects these changes, whilst also attempting to improve the effectiveness and consistency of strategies across waste practitioners, both in production and in implementation. It is intentionally less prescriptive than the previous version. This updated guidance is intended to aid and encourage more strategic and forward-looking IWSs to be developed that are integrated across all waste streams. It is the output of an updating process which has involved a series of consultation and feedback stages. The guidance recognises that waste management is not a straightforward process of retrieval and disposal. It requires a series of steps: pursuing opportunities for waste minimisation, re-use and recycling, waste treatment, packaging, storage, transport and then final disposal where required. The waste hierarchy should be used as a framework for waste management decision making to enable an effective balance of priorities including value for money, affordability, technical maturity, the views of stakeholders and the protection of health, safety, security and the environment. Consideration of the whole waste management lifecycle is central to the development and implementation of an IWS. The guidance has been developed from first principles, considering what a strategic document should be and what it should include, and draws extensively on the approach taken in guidance on developing Municipal Waste Management Strategies produced by Defra4 5. This national guidance has helped several hundred local authorities to deliver useful and deliverable strategies. Key to their deliverability, these strategies are forward-looking, seeking to understand the current situation, what the future might hold, and what that potential outcomes might mean in terms of requirements for the management of waste. This guidance is structured in the same way as the process of developing an IWS. Principally, it seeks to answer three key questions: • Where are we today? • Where do we want to get to and when? • What actions are needed to get there? Simply by answering these three questions, even in relatively loose terms, a meaningful strategy begins to emerge. Developing and refining that initial strategy concept, and producing a deliverable approach to waste management, with clear aims and objectives, timescales and processes, is the purpose of the remainder of this guidance.

4 - Defra, Guidance on Municipal Waste Management Strategies, July 2005. 5 - Defra, A Practice Guide for the Development of Municipal Waste Management Strategies, November 2005



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2 COMMUNICATION AND CONSULTATION

2.1 Regulatory input and consultation

The process of developing and establishing a strategy is part and parcel of the processes necessary to meet the regulators’ requirements. Indeed, the developing Environment Agency document ‘Regulatory Guidance Series, No RSR 2 - The regulation of radioactive substances activities on nuclear licensed sites’ states at paragraph 88: “We look to operators to demonstrate strategic planning for the management of all radioactive material and radioactive waste in an integrated way […]. Such planning must take into account all current and anticipated future arisings […]. Operators should maintain a clear strategic oversight of how they intend to manage the generation and disposal of radioactive waste over the lifetime of the facility.” This notwithstanding, communication and consultation with the regulators at the earliest practicable stage of development of the IWS is likely to identify key regulatory concerns for specific sites and/or companies. These then can be factored into the strategy development. It is essential to communicate and consult from the outset on the basis of ‘no surprises’. Regulators and other stakeholders should be made aware of the aims and objectives of the IWS and the systems of integrated waste management which will deliver it. The IWS should record what communication and consultation has been undertaken and the effect this has had upon the strategy development.

2.2 Stakeholder input and consultation

Beyond the regulatory communication, the development of an IWS will be of interest to other parties. These may include the: • Government and policy makers • Local Planning Authority; • Nuclear Legacy Advisory Forum (NuLeAF); Scottish Councils Committee on Radioactive

Substances (SCCORS); • Site Stakeholder Groups; • Client organisations; • Infrastructure and Transport interests; • Environmental and conservation interests; • Local Interest Groups; and • Other interested bodies. The development of the IWS should be communicated to relevant stakeholders and engagement carried out as necessary. The IWS document should record these engagement activities and record the effect consultation has had upon the strategy development.



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2.3 Accessibility

The IWS is a document that is likely to be read or requested by a number of bodies and persons. Effort should be made to ensure it is not protectively marked and is publicly available. There may be restrictions on the accessibility of the data which underpin the IWS. The IWS should therefore be clear from the outset as to which information is publicly accessible and how to obtain it, and likewise which is restricted and the reason why this is the case.



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3 OBJECTIVES AND AIMS

3.1 Where Are We? Where Are We Going? A strategy should be forward-looking and seek to accomplish a particular goal or goals. An overarching goal for NDA sites is set out in NDA Strategy, which is to ensure that wastes are managed in a manner that protects people and the environment, now and in the future, and in ways that comply with Government policies and provide value for money6. Waste producers should determine the goal for their integrated waste strategy. In the first instance, the strategy must set out what is happening at the waste producer’s sites within the strategy period. The strategy period for NDA sites is equivalent to the timescale covered by the Site Lifetime Plan (LTP). For non-NDA sites an appropriate and representative timescale could be established, with input from stakeholders. It is expected that the whole of this period is addressed within the strategy, although the focus will necessarily be more detailed for the short and medium term. The strategy will be informed by information from a variety of sources, including the LTP. The waste arising over the period is not specifically addressed here, it is the focus of the following sections, this section will set out the context that waste will be managed in. The strategy should include a summary of the direction of travel and the key milestones that will occur within the short, medium and longer time periods, up to site end state or the determined end point of the strategy. This will allow the reader to understand from the outset the context within which the management of waste is set, including integration between projects and facilities on and between sites. Necessarily, this summary is expected to be high level in nature, and could make use of diagrams or flow charts, both for ‘where are we’ and ‘where are we going’. Either way, it will be essential to note key assumptions.

3.2 Setting Objectives By setting key objectives, the strategy is given direction. Some relevant objectives will already be set out a higher level, for example in Government policy, national and NDA strategies for managing waste and guidance from regulators. Waste producers will already have objectives for their sites, some of which will also be relevant. This section is the place to collect and collate all the objectives that are appropriate to address through the strategy. In developing the objectives of the strategy, it is important that they are agreed at an appropriate level and subject to a suitable level of engagement. It is important to recognise the key constraints and the impact these have on the shaping of the IWS. Once agreed, the strategy should set out these objectives in such a way that both the aim and the reason(s) behind it are clear.

6 - NDA Strategy, April 2011



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3.3 The Waste Hierarchy A key objective should be to manage waste in accordance with the principles of the waste hierarchy. In assessing what wastes will be generated in the strategy period, it is important to remember that the primary drive for waste management is to avoid the generation of waste in the first place. Waste prevention is the most desirable level of the waste hierarchy (see Figure 3.1). The hierarchy is enshrined in Article 4 of the Waste Framework Directive 2008 (2008/98/EC) and has been applied to the UK nuclear sector through the Low Level Waste (LLW) Strategy7 covering the generation, storage and disposal of LLW, and the 2010 Joint Regulatory Guidance8 covering Higher Activity Wastes; and is applied to all non-radiological wastes through the Waste (England and Wales) Regulations 2011, Waste (Scotland) Regulations 2011 and the Waste Regulations (Northern Ireland) 2011. Figure 3.1 The Waste Hierarchy

UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry, NDA, August 2010 The IWS should demonstrate how a consideration of waste hierarchy, including waste prevention and minimisation, has been applied to all waste streams and forthcoming potential waste streams.

7 - UK Strategy for the Management of Solid Low Level Radioactive Waste from the Nuclear Industry, NDA, August 2010 8 - The management of higher activity radioactive waste on nuclear licensed sites - Part 3a Waste minimisation, characterisation and segregation - Joint guidance from the Health and Safety Executive, the Environment Agency and the Scottish Environment Protection Agency to nuclear licensees, February 2010



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3.4 Interaction with other strategies and plans

The IWS by necessity sits within a complex map of other strategies and documents. These will include requirements of the regulator(s), of the NDA and of Government. Figure 3.2 is intended to set out some of these relationships and shows the cascade from policy, through national strategy to the waste producer level. It also shows how the supporting information for the IWS does not need to sit within the IWS document itself. The IWS should provide a clear picture of those documents to which the IWS refers and where it fits within the hierarchy of strategy and planning. It should “sign-post out” to those documents and references where supporting information is held. Some of the justification and underpinning for the strategy will already be delivered to meet regulatory requirements. The regulator community support the demonstration of how the IWS interacts with these requirements. The IWS can also usefully set out how elements of Government policy and national strategy are being delivered at the waste producer level. A flow diagram might be used effectively to communicate these relationships.



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Figure 3.2 The relationship of an IWS to other aspects of waste management

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4 DATA GATHERING

4.1 What Wastes Do We Generate At Present? In order to be able to measure and understand progress, it is necessary to have a baseline against which to judge performance. Therefore, before any future planning is undertaken, it is necessary to know ‘where we are now’. The aim of the strategy is not to repeat all of this information – that should be left to the original sources, for example waste inventory records, which can be signposted in the strategy itself. Nonetheless, it should seek to demonstrate that the necessary understanding of the current position exists, that it is complete and the level of confidence in the data is good. This is not always a straightforward exercise, but should be undertaken diligently in order that: • all waste streams and materials which have the potential to become waste (including high,

intermediate and low level radioactive wastes, non-radioactive waste, discharges and potentially contaminated land) are identified and critically examined against the waste hierarchy;

• data (including volume/tonnage and specification) are present for these waste streams, where available;

• data validity is recognised and uncertainties are recorded; and • data gaps are identified. A concise summary of the data will be useful in the IWS document. It is not necessary to include the full data set within the IWS, and indeed, this can be counter-productive with respect to its principal goal. The IWS should however signpost where this information is available. Where data are uncertain, weak or absent, the IWS will need to include processes to assess these limitations and determine whether they are critical to the delivery of the strategy. The strategy should set out what action needs to be taken to improve the inventory data and the timescale on which action should be undertaken (see Section 6 for how these actions should be captured).

4.2 What Wastes Will We Generate In The Strategy Period? Future predictions of waste arising are the means by which waste management needs are determined. The also provide a comparator to the baseline. Data gathering should have regard to the timescales considered within the strategy: short; medium; and longer time periods up to site end state, and consider the step by step process set out above. As discussed above, a concise summary of arisings will be useful although it is not helpful for the IWS to repeat sources of data on current arisings but should signpost towards such sources. Highlighting where future waste management differ from the present will help focus aspects of the strategy going forward.



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5 CRITICAL EVALUATION OF WASTE MANAGEMENT OPTIONS

5.1 What Do We Do At Present? This section should set out how wastes are currently managed, in order to provide a baseline against which future performance can be judged. Current waste management routes should be set down regardless of whether they are deemed to be ‘good practice’ or not – what is important is to develop a complete and accurate picture of the current waste management approach as a whole. Section 5.3 of this guidance then considers the performance of each route. A diagram showing current waste routes may be useful for the reader.

5.2 What Will Be Needed In The Future? The data gathering exercise from Section 4 allows the determination of what new waste management capacity (where capacity includes infrastructure, skills and experience) may be required within the strategy period, including potential impacts on national facilities and opportunities for optimisation across the UK nuclear community. It is possible that existing waste management routes will no longer be sufficient and/or suitable for the future waste arisings, or that these routes are no longer optimal after a rigorous application of the waste hierarchy. The role of the IWS is to record the process by which current and future waste management capacity will be assessed, rather than to undertake this assessment. If it is determined that new waste management routes will be needed, then an assessment of these becomes an action to be undertaken as part of the strategy review cycle and one of the deliverables from the strategy.

5.3 Are existing routes and plans satisfactory? The IWS is an opportunity to review existing waste management routes and to consider future waste management routes against the background of ‘good practice’. This needs to include consideration of all aspects of the waste lifecycle, from characterisation right through to disposability. It is not necessarily a call for sites to undertake further options appraisal, however it is an opportunity to consider whether the existing options appraisal remains appropriate. The IWS should indicate the presence and location of existing underpinning reports and records of option appraisals to inform the reader what already exists and has already been completed. Where good practice is not being achieved, or where a management route needs to be developed, either because an old option has been found to be sub-optimal or because a new waste stream is anticipated, it will be necessary to carry out an exercise to select the most appropriate option. Typically this will be a requirement of obtaining a permit for a new waste management route, for example Best Available Techniques assessment in England and Wales, or Best Practicable Environmental Options / Best Practicable Means assessment in Scotland and Northern Ireland.



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Once again, the role of the IWS document is to record the need for such action and to set out how this will be done, by when and with what aims, and to record the output from such exercises where they have informed the strategy. Where such requirements are identified, they are carried forward to Section 6.1, whilst consideration of strategy robustness and potential fall back options may be linked to Section 6.2. The process of optioneering is not prescribed by this document, but guidance is provided by both the regulators and the nuclear industry, including: the Environment Agency’s Regulatory Guidance Series9; the joint guidance on the production of Radioactive Waste Management Cases10; and, the nuclear industry code of practice on identifying and implementing ‘Best Available Techniques’11.

9 - Regulatory Guidance Series, No RSR 2 - The regulation of radioactive substances activities on nuclear licensed sites, Environment Agency, March 2010 10 - The management of higher activity radioactive waste on nuclear licensed sites Part 2 Radioactive waste management cases - Joint guidance from the Health and Safety Executive, the Environment Agency and the Scottish Environment Protection Agency to nuclear licensees, February 2010 11 - Best Available Techniques (BAT) for the Management of the Generation and Disposal of Radioactive Wastes A Nuclear Industry Code of Practice, December 2010



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6 HORIZON

6.1 Key Deliverables, Decisions and Required Timescales for Delivery The focus of the IWS to this point has been to understand and to assess the waste arisings at the site and how these will be managed. It is to be expected that changes to existing circumstances will be needed at some point. The relative priority of these changes, and the speed with which they need to be made, must be considered in the context of all other legislative and regulatory drivers at the site. This section of the IWS should take the outcome of the analysis undertaken in Sections 5.2 and 5.3 and decide (most likely using some form of consultation) which are to be delivered and on what timescale. This then should be recorded within the IWS. A decision calendar approach may be a useful way of communicating this to the reader. It is important that the short, medium and longer time periods up to site end state are all considered here. Clearly, the short term deliverables are likely to be more detailed. Nevertheless, it is important to capture the long term goals as these are the drivers for change and underpin the whole process.

6.2 Risk and Opportunity Management in Strategy Delivery As with all long term strategies, there are uncertainties associated with the implementation of an IWS. A certain amount of contingency planning will be required. The likely risks to the delivery of the strategy should be examined and explored in this section, for example, the potential for a current waste route to become unavailable. In addition, the potential opportunities that delivery of the strategy offers should also be recorded. Once risks and opportunities are known, then mitigation or enablement procedures can also be identified and monitoring put in place. In particular, the deliverables identified in Section 6.1 are likely to have risks and opportunities associated with their progress. It is not anticipated that this section of the IWS be a re-examination of all site risks and hazards. Rather it should be a simple record appropriate to the strategy, possibly in tabular form, to identify what actions are being taken as a result of the risks and opportunities identified. Where risks associated with the implementation of a strategy are significant there should be fall back options identified within the IWS.

6.3 Action Planning

Broadly speaking, the IWS process has the function of identifying gaps and uncertainty. Sections 6.1 and 6.2 should identify a number of actions required to fill the gaps and address uncertainty. Some of the actions will be delivered through other existing processes, for example the TBuRD process will identify and resolve technical issues. Actions that will not be addressed elsewhere, likely to be more associated with addressing management and process gaps, should be identified in an IWS Action Plan.



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It is recommended that an Action Plan for the IWS is developed to: • detail actions identified by the strategy; • demonstrate how the actions will deliver the aims of the IWS and therefore why they are important; • assign owners; • identify dependencies and enablers; • identify how progress is to be tracked and recorded; • track progress; and • record completion. In this way, success can be documented, residual actions identified and the operator can learn from experience. The IWS Action Plan will inevitably focus on the near term activities and progress should be reviewed more regularly than review of the whole IWS. Indeed this should be seen as the ‘active’ portion of the document. It is recommended that a process for the regular review of the Action Plans is established and that reviews occur at least once every 12 months.



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7 MONITORING AND EVALUATION We have proposed in this guidance that under normal circumstances a three-year cycle should be appropriate for updating an IWS document. In between this cycle there is a need to review progress against the IWS action plan. Figure 7.1 sets out the different timescales referred to in this guidance and some of the issues to consider are set out in this section of the document. Figure 7.1 Strategy and Action Plan review cycles

7.1 IWS review cycle

The whole IWS must remain relevant to the activities occurring on site. The IWS should set out a timescale for the full revision of the strategy, the process by which this will be accomplished and by whom. As a minimum reviews should be undertaken on a cycle of no more than three years. At this time all aspects of the IWS should be revisited, including the key objectives. Action Plans should be reviewed at least annually. This will enable the IWS as a whole to remain up to date and to demonstrate progress without the need for an annual rewrite of the entire strategy. The key factor is that the IWS remains current. It is foreseeable that events (both external and internal) occur within the three year review cycle that renders the IWS out of date. In particular, long term plans for national repositories may vary and affect the assumptions in the IWS. Such issues may include, but are not limited to:



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• management structure change; • management system change; • changes in policy; • changes in legislation and/or regulation; • changes in production or waste programmes progress; • new scientific or technical research or other advances; • sudden non-availability of a waste management route; and • changes in surrounding (or waste management route destination) land-use or designation. The IWS should therefore record events such as these that would trigger a mid-cycle review of the whole IWS.

7.2 Indicators and metrics The IWS should set clear indicators and metrics against which progress will be measured. Review of the progress against the IWS Action Plan will demonstrate progress in developing the IWS and ensuring the capability and capacity to manage waste. However, it is also important to demonstrate that the IWS is having the expected impact on waste management. The IWS document should set out what waste metrics the operator intends to use to monitor the affect of the IWS and demonstrate that the stated aims of the strategy are being realised. Waste producers could consider the use of a “benefits realisation” approach in this respect, such as that set out in the Office for Government Commerce’s Managing Successful Programmes.

7.3 Reporting and audit An IWS developed as outlined in this document will provide a clear and explicit roadmap of how an SLC is setting its waste management priorities and the journey the site expects to follow. Thus, it will be an invaluable guide for regulators and other stakeholders during interactions on waste management issues between operators and regulators. Within the NDA estate there is a contractual obligation to produce an IWS. The IWS should outline the SLC audit arrangements to establish whether it is delivering against its stated aims, the audit process to be carried out, and its frequency. The IWS should provide details of how progress in waste management against the IWS will be reported and made available in the public domain. This will ensure that the IWS is seen as linking the high level principles and priorities of radioactive and non-radioactive waste management with operational progress and site cleanup.

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