EIADR PRE-APPLICATION OPINION SCOPING REPORT / RDPP 0723 Issue 4

CONSORT RESEARCH REACTOR

ENVIRONMENTAL IMPACT ASSESSMENT DECOMMISSIONING REGULATIONS

PRE-APPLICATION OPINION SCOPING REPORT

Ref No: ICRC/R/35

Document History

Issue / Date
(DD/MM/YY) / Page(s) / Amendment / Review
Date / Reviewed By
1 / 08/01/07 / All / First issue
2 / 19/02/07 / All / Amended in line with comments received from Imperial College London
3 / 23/03/07 / All / Amended in line with comments from Decommissioning Working Group (02-03-07) & initial comments from HSE.
4 / 4/04/07 / All / Amended with comments from John Earp; insertion of text from MSM Solutions pages 2-8; revision of VLLW definitions against ref.7; adjustment of references.
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EIADR PRE-APPLICATION OPINION SCOPING REPORT / RDPP 0723 Issue 4

TABLE OF CONTENTS

1Summary......

2Introduction and Scope......

3Site description......

4Description of the Project......

5Proposed Content of the Environmental Statement......

6Current Uncertainties in Information......

7References......

8Appendix I – Site Plan......

9Appendix II – Options Assessment for Decommissioning......

10Appendix III – Stakeholders Involved in Consultation......

11Appendix IV - Proposed Decommissioning Methods......

12Appendix V – Radioactive Discharges and Discharge Limits......

13Appendix VI – Transport Requirements......

14Glossary......

Consort research reactor

EIADR PRe-application opinion scoping report

ImperialCollege is applying to the Health and Safety Executive (HSE) for permission to decommission Consort, a small research reactor that has, for over 40 years, operated from ImperialCollege’s Silwood Park Campus in Berkshire. In making this application it seeks to demonstrate to HSE that the environmental impact of the proposed work will be adequately assessed.

This document is the first stage of seeking that permission and sets out the known environmental impacts of the proposed decommissioning project and areas for further quantification. It is intended to help HSE and external stakeholders express their opinions on the scope and contents of a full environmental impact assessment.

The process of consultation that ImperialCollege is following is prescribed by the Nuclear Reactors (Environmental Impact Assessment for Decommissioning) Regulations 1999 (SI 1999/2892) as amended by the Nuclear Reactors (Environmental Impact Assessment for Decommissioning) (Amendment) Regulations 2006 SI 2006/657).

1Summary

1.1Consort

For over 40 years ImperialCollege has operated a small nuclear reactor at its site in Berkshire. The reactor, which has a core or fuelled volume about the size of a small fridge and is housed in a purpose built centre, is used to provide irradiation services to medical and other industries. As technology has moved on and alternative approaches have been found the demand for its services has fallen and the College is planning to close the facility and decommission the reactor.

1.2The process of seeking permission to decommission

Legislation(ref. 1) requires that before a nuclear reactor of this type can be decommissioned the environmental impact of that work is quantified as being below acceptable limits.

To meet this requirement ImperialCollege is following a two stage approach:

  1. It will request an opinion from HSE on the environmental information it requires to grant a consent to decommission Consort. This request for an opinion is supported by this report which sets out the proposed scope of a full Environmental Statement and an initial view of the environmental impacts of decommissioning.
  2. Taking account of the views of stakeholders and HSE, ImperialCollege and its expert advisors will produce a statement that describes and quantifies the environmental impact of the decommissioning project.

The final environment impact assessment (EIA) will be submitted to HSE who after consulting with stakeholders and being satisfied that the environmental impacts have been adequately addressed will grant ImperialCollege permission to decommission.

This document, known as a pre-application document, provides a preliminary assessment of the environmental impacts of decommissioning and sets out the information that will be included in the environmental statement.

1.3The initial view of the environmental impact of decommissioning consort

At this stage the environmental aspects of decommissioning Consort are believed to be: discharges to water, discharges to air, solid waste disposals, land quality, resource use, transport, nuisance, biodiversity and heritage. Others may emerge from the consultation but in these areas the initial results of the scoping assessment suggests that the environmental impacts of the proposed project are likely to be minimal. This is due to the small scale of the decommissioning activities associated with such a small reactor, and the mitigation measures that will be put in place.

1.4Areas of certainty, and areas for further work

For some environmental aspects, non-radioactive discharges to water, discharges to air (excluding dust emissions), resource use, transport, nuisance, biodiversity and heritage, there is sufficient information available at this pre-application stage to suggest that their environmental impact will be negligible, and that the remediation processes will provide a best practicable environmental option, with disposals following best practical means. Other than a review to ensure that the current understanding of the project and environmental baseline has not altered, no further work will be done in these areas and the statements in this report will be re-made in the final EIA.

For other environmental impacts, namely radioactive discharges to water; dust emissions to air, land quality, solid waste disposals, and decommissioning accident scenarios, further work is required and the results of this will be reported in the final EIA.

There are uncertainties that may affect the information provided in this pre-application document. These include the timing of reactor closure, the decommissioning techniques, the waste routes, waste volumes, the degree of potential land contamination, and potential decommissioning accident scenarios. Where these uncertainties have a material affect on calculations in this report, worst case scenarios have been applied to estimate the environmental impact.

2Introduction and Scope

In line with current legislation(ref. 1) Imperial College of Science, Technology and Medicine (Imperial College London) requests a pre-application opinion from HSE on the information required in an environmental statement relating to the future[1] decommissioning of Consort, a research reactor at Silwood Park campus near Ascot.

This document, through which the licensee requests that opinion, has been prepared by UKAEA on behalf of Imperial College London as part of the Reactor Decommissioning Planning Project (RDPP). It provides a description of the site, the reactor, the decommissioning plan, and the environmental aspects[2] of the project to be assessed. It describes the intended actions to generate further information required by a full Environmental Impact Assessment (EIA).

To prepare this report, Imperial College and its advisors have followed the process illustrated in figure 1. The report identifies the environmental aspects that need further assessment for the EIA, and those that require no further work. Note: any aspects classified as requiring no further assessment will still be reviewed again to ensure that the current understanding of the project has not altered so as to affect the preliminary assessment.

In order to conduct this initial assessment, this pre-application provides a description of the baseline environmental conditions against which any environmental impact will be assessed. This baseline is used at this scoping stage in order to compare the potential environmental impact of the project by providing a comparison with either

  • the current physical state of the environment (e.g. land quality, the sensitivity of the receptor such as the presence of protected species, the tranquility of the area) or with
  • the environmental impact currently resulting from normal operations (e.g. from radioactive discharges or electricity use).

Under EIADR 99, defuelling is not normally treated as part of the environmental statement as it is considered to be a normal operation and not part of decommissioning project.

The future environmental impact assessment will primarily focus on those aspects for which this initial assessment indicates a greater than negligible environmental impact, or where there is not enough information currently available in order to make a scoping impact assessment.

3Site description

3.1Site Location

The Imperial College London Reactor Centre and adjoining EASbuilding are located on the ImperialCollegeLondonSilwoodPark campus, near Ascot, Berkshire, at Ordnance Survey grid reference SU 946689 and approximately 40 km west of London. SilwoodPark campus has an area of 120 ha and is surrounded by park land and small villages. The nearest village is Sunninghill, about 1 km away, with the town of Ascot being approximately 5 km away. The population of the Sunninghill and South Ascot ward is approximately 6500, and the population of the Ascot and Cheapside ward is approximately 5100 (ref. 2). The location of SilwoodPark is shown in the Ordnance Survey map extract (Figure 2).

Figure 2: Ordnance survey map extract showing the location of SilwoodPark (©Crown Copyright. All rights reserved. [UKAEA - 100021164])

Historically, SilwoodPark was undeveloped park land, with a history that can be traced back to 1362. It later formed the grounds of a manor house, prior to its purchase by Imperial College London in 1948.

The majority of the site is not nuclear licensed, being primarily used for environmental monitoring and fieldwork. The location of the Reactor Centre within SilwoodPark is shown in the site planin Appendix I.

3.2Site Facilities

The Reactor Centre was built in 1964. The nuclear licensed area comprises only the reactor building and the land immediately around it within the fence, as shown in Figure 3.

Figure 3: Schematic map of site showing nuclear licensed site boundary

3.3The CONSORT Reactor

CONSORT is a low power (100 kW) pool-type nuclear research reactor, and is moderated, cooled and partially shielded by light water. It is a relatively small plant, approximately 10 metres in height and width. It is housed in a purpose built reactor hall which is equipped with a ventilation system and a travelling crane. Designed by ImperialCollege and General Electric Company, the reactor was commissioned in 1965 following a government drive to increase research and training facilities in nuclear science.

Waste water arising from reactor operations and maintenance activities is conveyed to a 2000 gallon holding tank (approximately twice the capacity of the reactor vessel) and is in a bunded underground pit just outside the west wall of the reactor building. The approved disposal route for the water is for it to be pumped to thisholding tank and monitored before pumping to the sewer under a Radioactive Substances Act (RSA) 1993 authorisation. Waste water is accumulated prior to its discharge which is carried out at least once every three years.

The reactor ventilation system is connected to a small blower mounted on the ledge of the reactor shielding to draw air in parallel from the pool surface, and from the experimental facilities and instrument tubes. Exhaust airis filtered and discharged under RSA authorisation, via separate ducting within the building ventilation stack.

CONSORT is primarily used for teaching, research, and analysis, including:

  • Teaching, training and academic research (both for ImperialCollege and other educational establishments, a learned society and government departments here and abroad);
  • Providing reactor neutron detector calibration services (supporting UK electricitygeneration and reactors in 5 other countries);
  • Producing radioactive products for use in research and development by industries such as the pharmaceutical and medical industry (for the development of new drugs) and the oil exploration industry;
  • Trace element analysis research and service work (e.g. detection of contaminants in food packing);
  • Environmental monitoring services (e.g. detection of very small amounts of uranium in environmental samples).

3.4EASBuildings and Workshop

The adjacent EAS buildingsare physically linked to the Reactor Centre via a workshop area but they are not part of the nuclear licensed site. They were added between 1969 and 1971, and contain two general-purpose laboratories, two radiochemical laboratories, a seminar room, counting rooms, workshop and offices. They have been used during its lifetime for a range of academic studies related to the reactor.

3.5Physical Characteristics of the Site

3.5.1Vegetation

The layout of the area surrounding the Reactor Centre is shown in the schematic map (Figure 3). There are a number of trees close to the reactor building, and a wooded grass bank is present to both sides. The flora and fauna located near to the Reactor Centre are discussed further in the Biodioversity and Heritage section 5.2.7.

3.5.2Geology

The Reactor Centre is situated on surface gravel and Bagshot Sand at 20-25 m elevation above impervious London Clay. Groundwater is thought to flow through the sand towards the north west and into the (unnamed) stream running on London Clay from Silwood Lake to Virginia Water and then on via the River Bourne to the River Thames. (See OS Pathfinder 1189 Bracknell and Ascot and BGS 1:50000 sheet 269 Windsor solid and drift edition).

The water table is normally likely to be above the elevation of the London Clay, as groundwater continually seeps into SilwoodLake (except during long dry periods).

4Description of the Project

4.1Decommissioning Strategy

The intent is that the CONSORT research reactor will be shut down, de-fuelled and decommissioned, and the site will be delicensed and available for light industrial use; that is the site will no longer be used for purposes for which a nuclear licence is required, and will present no danger from ionising radiations as defined by the HSE (ref.3).

Five strategic options for the decommissioning project have been considered in the Decommissioning and Waste Management Strategy (ref. 4). The options mainly differ in terms of the timing of decommissioning, and are discussed in more detail in Appendix II. The three preferred options that are considered to be acceptable in terms of environmental impact, government and Nuclear Decommissioning Authority (NDA) policy and practicability are: option one – to shut down promptly, defuel and decommission as soon as practicable to a delicensable condition; option two - to shut down in 2008, defuel after two years cooling and decommission immediately to a delicensable condition;and option three - to continue operations until 2017 before shut-down then defuel and decommission immediately to a delicensable condition.

The assessment of environmental impact in this pre-application document is considered to be applicable toall three of these options as they only differ in terms of when the decommissioning project will commence: the environmental impact of continued operations is considered to be low, so there would be no significant additional impacts resulting from option three.

For the purposes of planning, it is assumed that CONSORT will shut down in 2008, with decommissioning work starting in 2009. Decommissioning of the reactor tank, the reactor hall and all above and below ground structures will be complete so as to allow delicensing by 2013. The adjacent (non-licensed) EAS buildings, containing offices and radiochemical laboratories, will also be demolished. It is expected that the EAS buildings will be used for office accommodation during the project and subsequently demolished. For completeness, the demolition of the EAS buildings will be included within the environmental statement, although it is outside the licensed site.

4.2Proposed Decommissioning Plan

The proposed plan for defuelling and decommissioning CONSORT, based on current understanding of the issues involved, is summarised below. It will be subject to further detailed planning and the resolution of a number of uncertainties.


Figure4: The main stages involved in the decommissioning of CONSORT

Following post operational cleanout, decommissioning will be carried out in two phases:

  • Phase 1: Preliminary works and fuel removal.
  • Phase 2: Reactor dismantling, building demolition, site remediation and delicensing.

It is envisaged that separate specialist contractors will be employed to carry out certain specific tasks such as fuel unloading and building demolition under the overall control of a single implementation contractor working in partnership with Imperial College London as the site licence holder. Figure 4 summarises the main stages involved in the decommissioning of CONSORT.

CONSORT will be decommissioned using tried and tested techniques for surveying and monitoring, cutting and size reducing of large items of equipment, decontaminating surfaces and packaging wastes. An outline methodology of typical decommissioning activitiesisgiven in Appendix IV. Detailed methods will be decided post closure by the decommissioning contractor and will be used as the basis for the detailed Decommissioning Safety Case.

4.3Stakeholder Engagement

4.3.1 Stakeholder Consultation Strategy

ImperialCollegeLondon, in decommissioning CONSORT, seeks to achieve the minimum disruption to stakeholders’ environment, lives, health and businesses. The College and the team responsible for decommissioning is committed to taking careful account of views expressed through all means of consultation. It will ensure relevant explanations and reassurances are given and where necessary will amend its approach to meet requests of stakeholders. To achieve this, the College will give those affected the opportunity to review and shape its plans. A full list of statutory and non statutory consultees is given in Appendix III.

The primary vehicles which will be used for working with stakeholders are:

  • Statutory consultations undertaken on our behalf by HSE. This will involve a range of national and local organisations.
  • On-going dialogue with the Silwood Park Campus Committee and the Silwood Park Safety Committee. This will involve those living and working on the campus.
  • The internet and other public media through which our plans will be made available to the wider public.

In addition to these formal consultation vehicles, Imperial College London will pay special attention to the stakeholders on whom impact will be highest, namely those employed to operate and maintain CONSORT; the Reactor Centre’s customers and the College Management Board. Dialogue with all has been on-going for more than two years and the College has made commitments about giving maximum notice of change.

4.3.2 Stakeholder Consultation Plan

In order to engage effectively with stakeholders throughout the proposed decommissioning project, Imperial College London will:

  • Work with HSE whose stakeholder engagement process involves:
oThe College notifying people, via the local press and other methods, of this pre-application consultation;
oDistributing this report to all listed consultees and those requesting it;
oSeeking views of stakeholders on the approach to decommissioning;
oDistributing an environmental statement and seeking stakeholder views on the impact of our plan;
oWorking with HSE to amend the plan so that it addresses the concerns raised by stakeholders.
  • Schedule a series of quarterly meetings of the Campus and Safety Committees. The minutes of and actions arising from these meetings will appear on the College website.
  • Continue dialogue with employees and their Union representatives through line managers and at quarterly staff briefings.
  • Continueto work with customers through one-on-one meetings.

4.4Other relevant documents