- Site: Sellafield
- IR number: 20-088
- Date: December 2020
- LC numbers: 32
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.
This record describes the outcome from a planned compliance inspection at the Waste Vitrification Plant (WVP) on the Sellafield site. The purpose of this inspection was to confirm Sellafield Limited’s (SL) compliance to its arrangements for licence condition (LC) 32: Accumulation of radioactive waste. This inspection was carried out in conjunction with the Environment Agency’s inspection of the facility’s application of Best Available Techniques (BAT).
Due to the current coronavirus (COVID-19) pandemic risks, the intervention was undertaken remotely supplemented with some on-site evidence gathering by the ONR Site Inspector prior to this intervention. The inspection has been carried out in line with the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division’s regulatory approach to the COVID-19 pandemic.
In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has put in place variations to its corporate arrangements which affect its arrangements for compliance. Prior to this intervention, ONR has reviewed the relevant variations and was satisfied that the variations had no significant impact on the inspection.
Interventions Carried Out by ONR
This inspection was carried out against LC 32. It sought to seek evidence of compliance against this licence condition.
The inspection began with a presentation by the licensee to provide an overview of their compliance with LC 32 and Sellafield’s corporate arrangements. This was followed by further discussion of specific waste streams. This was supported by evidence that had been requested in advance and supplied by the licensee. This included photographic evidence provided by the ONR Site Inspector during a plant walkdown in advance on this intervention.
This inspection was focussed on secondary waste produced in the facility i.e. the in-cell maintenance waste produced by facility operations, rather than the waste that the WVP accepts to vitrify as part of its normal operation. The inspection focussed on the following areas:
- Implementation of the Sellafield Corporate LC 32 arrangements;
- Local arrangements for the management of radioactive waste and waste inventory;
- Waste management, including minimisation and characterisation;
- Waste records;
- Competence of persons involved in the implementation of the LC 32 arrangements and records relevant to LC 32.
Explanation of Judgement if Safety System Not Judged to be Adequate
This section is not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
With regard to local arrangements for radioactive waste management we are of the opinion that a significant inventory of radioactive waste exists in the cells, but that the facility has adequate local arrangements to export this waste and plans in place to improve compliance with LC32. Good progress has been made with regard to filter exports and improvements have been identified in other areas to enable the facility to recover from this position.
With regard to inventory of radioactive waste we note that significant effort was made in 2018 to evaluate the inventory, however a current consolidated inventory is not currently available. We advised that the inventory should be updated and maintained in line with ONR’s expectations, noting this will be of particular importance as the rate of waste exports is increased going forward.
With regard to roles and responsibilities we are of the opinion that the facility has suitably qualified and experienced personnel in place for the management of radioactive waste in the facility and found all training records to be in date.
Conclusion of Intervention
On the basis of evidence in relation to LC 32 the inspection team judged that the licensee had adequate arrangement for compliance against this licence condition and has assigned an inspection rating of GREEN.
However, we note that a significant inventory of waste exists, and this inspection rating recognises recent improvements in the arrangements at the facility and the development of improvement plans to recover from this situation. This will be followed up through routine regulatory engagement at Level 4 meetings and the next LC 32 compliance inspection.