- Site: Sellafield
- IR number: 21-014
- Date: May 2021
- 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. One such inspection was performed to assess the Special Nuclear Materials (SNM) Value Stream’s compliance with Sellafield Ltd’s (SL’s) corporate arrangements for Licence Condition (LC) 32 (Accumulation of radioactive waste). The LC inspection focussed on SNM North (N) activities.
Interventions Carried Out by ONR
On 11 May 2021, I carried out a licence condition compliance inspections of the SNM facilities. The inspection comprised discussions with SL staff, review of plant records and other documentation, and a plant inspection. I was supported (remotely be telephone) by an ONR Nuclear Liabilities Regulation (NLR) specialist inspector and an ONR Safeguards Inspector. The LC 32 inspection was undertaken jointly with the Environment Agency (EA). A member of SL’s Nuclear Intelligence and Independent Oversight (NI&IO) team also participated in the inspections.
LC 32 requires the licensee to make and implement adequate arrangements to minimise, so far as is reasonably practicable, the rate of production and total amount of radioactive waste accumulated, and for recording the waste.
As part of my preparation for the delivery of this intervention, I used the current version of ONR technical inspection guidance documentation NS-INSP-GD-032.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection, I sampled documentary evidence relating to the generation, storage, and recording of accumulations of waste. I observed that the licensee has a good understanding of the arrangements for the management of waste. On a sample basis evidence was seen that relevant role holders had completed the training required by the SL Corporate arrangements. I undertook a plant inspection to confirm the extent of accumulated waste on plant, and to establish if the licensee is adequately managing the accumulation and safe storage for onward processing on site and eventual disposal.
Throughout the intervention evidence was seen that progress had been made since the last LC 32 inspection in February 2020, and that past regulatory advice has been acted upon. SNM(N) recognise the need to remain vigilant with regard to managing the waste, and that there are further improvements they can make. Some minor shortfalls were noted during the plant walk-down regarding the storage of waste. SNM(N) have raised condition reports to ensure the maters are appropriately addressed.
SNM(N) have not been able to export some Low Level Waste brick rubble in a timely manner. As part of routine regulatory business, an ONR Nuclear Liabilities Regulation Inspector will engage with SL corporately to understand the underlying causes. This may lead to the raising of a Regulatory Issue to provide oversight.
I found that no excess of accumulation of routine Low Level Waste had occurred despite the COVID-19 challenges. However, SNM(N) recognise that during the past year there, have at times, been challenges with regards to house-keeping standards at the point of source where waste is generated. However, I found that SNM(N) are in the process of implementing appropriate actions to reset the expectations regarding house-keeping and to bring about improvements.
SNM(N) have identified some further improvements associated with procurement and storage of goods for projects, operations, and maintenance activities. The intention being to further reduce the amount of goods needed to be stored, and avoid the creation of unnecessary waste. In addition, SNM(N) will be producing a new live waste inventory and disposal programme.
On behalf of the SNM Safeguards Inspector, I confirmed that the data recorded in a SL database was consistent with the records kept with two drums of safeguarded material.
Conclusion of Intervention
I judged from the evidence sampled that SL has effectively implemented its arrangements for compliance with LC 32 for SNM and I have assigned an inspection rating of Green (no formal action) for compliance against this LC. One level four (i.e. lowest level) regulatory issues has been raised in order to gain oversight of SNM(N) plans for generating a new live waste inventory and disposal programme.
From the evidence sampled, the ONR Safeguards Inspector gained assurance of compliance with Regulation 29(1) of the Nuclear Safeguards (EU Exit) Regulations 2019. He identified no significant matters that merit specific follow-up with SL Nuclear Materials Accountancy and Safeguards.