- Site: Sellafield
- IR number: 21-054
- Date: July 2021
- LC numbers: 32
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2021/22, identifies the Licence Conditions (LCs) that will be inspected during this period. This intervention was postponed from the 2020/21 plan due to the COVID-19 pandemic and national lockdown.
The purpose of this inspection was for ONR to determine the adequacy of the implementation of SL’s arrangements for compliance with LC32 (Accumulation of Radioactive Waste) at the Encapsulation Plants, which consist of; the Magnox Encapsulation Plant (MEP), the Waste Encapsulation Plant (WEP), and; Encapsulated Product Stores 1-3 inclusive (EPS1, EPS2 and EPS3).
The overall adequacy of SL's site-wide LC32 arrangements is considered separately in other ONR interventions.
Interventions Carried Out by ONR
I, the Site Inspector for Effluent and Encapsulation Plants supported by a Nuclear Liabilities Regulation (NLR) Specialist Inspector, carried out a planned LC32 compliance inspection at the Encapsulation Plants.
Due to WEP being in a period of outage at the time of this inspection, the main focus was placed on the compliance of MEP and EPS 1-3.
The inspection comprised discussions with SL staff, a review of records, sampling of information provided prior to and during the inspection and a plant inspection.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a system-based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
I found that the Encapsulation Plants had adequately implemented the Sellafield Limited arrangements for LC32, including, where applicable, variations made in response to the COVID-19 pandemic and national lockdowns.
The provided arrangements for LC32 contained some weaknesses which are subject of a pre-existing Regulatory Issue. As this residual matter is not the responsibility of individual facilities, the NLR Specialist Inspector will take this forward with SL’s Process Owner for LC32 at the corporate level as part of normal regulatory business.
Through the process of sampling the supplied arrangements, discussions with plant staff and a plant walk down, SL provided evidence of the following:
- The Encapsulation Plants had appropriately approved local arrangements in place to support compliance with LC32,
- Relevant staff were aware of the Waste Management Hierarchy and how it related to their work with both Intermediate Level Waste (ILW) and the plant’s secondary wastes that are generally of a lower category (i.e. Low Level Waste (LLW), and Exempt),
- Adequate awareness that ONR’s expectations in respect of LC32 apply equally to solid, aqueous and gaseous radioactive wastes,
- Relevant staff were aware of the SL Mandatory Standard for Management of Wastes (SLC 2.10.01) and the duties placed upon them within SLC 2.10.01,
- Arrangements were either in place or under development to record where radioactive waste was stored within the Encapsulation Plants, including the amounts, durations and form of storage,
- Good awareness of the contribution the Encapsulation Plants will make to the future mission of Sellafield and overall priorities of ONR in respect of LC32 (e.g. to enable POCO and High Hazard Risk Reduction)
- Dedicated lay down areas were provided for the temporary storage of radioactive wastes on the plant and the majority of observed radioactive wastes were found to be located within those areas,
- A stated intent from senior leadership to drive positive cultural change in respect of the facility’s waste management performance, with self-identification of aspects in need of improvement.
The following shortfalls were identified:
- SL could not provide a justified and documented organisational design in respect of the management of radioactive wastes, including the key roles set out in Mandatory Standard SLC 2.10.01, which was a shortfall against NS-TAST-GD-065,
- Extant holders of SQEP posts such as the Plant Solid Waste Coordinator were found to have incomplete training, which was a shortfall against NS-TAST-GD-025,
- Some relatively small accumulations of secondary wastes were stored in locations that were not nominated for that purpose, which was a shortfall against NS-INSP-GD-032
- The MEP Waste Disposal Tracker did not provide a fully comprehensive data set as regards the amounts, durations and form of storage of waste on the facility, which was a shortfall against NS-INSP-GD-032,
- The totality of electronic data and paper-based operational records for the radioactive wastes held in EPS 1-3 were co-located with no fire segregation in place, which was a shortfall against NS-TAST-GD-033 and the relevant good practices found in NDA’s guidance document ‘Managing NDA’s Information Requirements’ (IMP06).
SL accepted these findings and a level 4 (lowest level) regulatory issue has been agreed to track follow up actions with respect to the identification of LC32-related SQEP roles and completion of relevant training. Since SL had previously self-identified these issues, in my judgement this was not a significant enough finding to affect the inspection rating.
The findings were shared with, acknowledged, and accepted by the Encapsulation Plant management as part of normal inspection feedback.
The Environment Agency representative participated in the full scope of the inspection and committed to produce a separate RASCAR that will capture emergent findings of relevance to his vires.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judged that the Encapsulation Plants had adequately implemented SL’s arrangements for LC32, and it is my opinion that an inspection rating of Green (no formal action) is therefore appropriate.