- Site: Sellafield
- IR number: 21-129
- Date: November 2021
- LC numbers: 6, 25, 26, 32
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste Division. The planned inspection schedule for 2021/ 22 identifies the Licence Conditions (LCs) that will be inspected during this period.
This record describes the outcome from two planned compliance inspections across the Legacy Ponds value stream. The first inspection specifically targeted the Pile Fuel Storage Pond (PFSP) complex on the Sellafield Site. This intervention targeted PFSP as it is a high hazard facility, and its continued safe operation is key for continued nuclear safety of the Sellafield site. The purpose of the inspection was to determine the adequacy of implementation of Sellafield Limited arrangements for compliance with its corporate arrangements for Licence Conditions (LC): LC 6 (Documents, records, authorities and certificates), 25 (Operational records), and 32 (Accumulation of radioactive waste).
The second inspection specifically targeted the First Generation Magnox Storage Pond (FGMSP) complex on the Sellafield Site. This intervention targeted FGMSP as it is a high hazard facility, and its continued safe operation is key for continued nuclear safety of the Sellafield site. The inspection was unannounced, and the duty holder was only made aware of the inspection as it commenced. The purpose of the inspection was to determine the adequacy of implementation of Sellafield Limited arrangements for compliance with its corporate arrangements for Licence Condition (LC) 26 (Control and supervision of operations).
Interventions Carried Out by ONR
The first inspection sought evidence of compliance against LCs 6, 25 and 32 and were linked by consideration of a common theme of Sellafield Limited’s ability to maintain on records, radioactive material inventory, and the storage and disposal of radioactive waste. The inspection concluded with a de-brief with the Operations Manager for PFSP and inspection support team.
The second inspection sought evidence of compliance against LC 26 and focused on the available control and supervision along with general operational standards and housekeeping. The inspection concluded with a de-brief with the head of operations for Legacy Ponds and the plant DAP.
The intervention comprised discussions with personnel, a plant walkdown, and review of documents.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety system-based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
In relation to LC 6 PFSP demonstrated: the provision of their Record Retention Schedule and local record register; the Record Controller has been trained in line with the role profile and the records sampled were retained as listed and accessible. Some records locally archived were missing from the local record register or were in inappropriately filed, however this was considered minor.
In relation to LC 25 I am content that PFSP have up to date and accurate inventories for the radioactive material (including waste) held on the facility.
In relation to LC 32 PFSP have identified the challenges preventing them from effectively managing radioactive waste and successfully implemented improvements. Progress disposing of radioactive waste was confirmed by Sellafield Limited Nuclear Intelligence and Internal Oversight (NI&IO). Walkdowns and audits are being undertaken in line with Sellafield Limited arrangements. Storage of chemicals should be improved.
In relation to LC 26, during the unannounced plant visit of FGMSP, the Licensee was able to clearly demonstrate the control and supervision in place for operations. Therefore, I found that compliance with Sellafield Limited’s corporate arrangements, however, I found minor non-compliances in waste management, which were accepted, and a condition report was raised to ensure action was taken to address the minor non-compliances, therefore further action was not considered proportionate.
I identified minor shortfalls in relation to LC 6 and LC 32. I raised these as an ONR Regulatory Issue at Level 4.
Conclusion of Intervention
I consider in respect of LC 6, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here.
I consider in respect of LC 25, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here.
I consider in respect of LC 32, having taken into account the minor non-conformances with regulatory expectations for storage of radioactive waste, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here.
I consider in respect of LC 26, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here.
I identified some findings for which I have raised as an ONR regulatory issue at Level 4 to track SL’s progress of these matters.