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Licence Condition 32 'Accumulation of radioactive waste' compliance inspection

  • Site: Sellafield
  • IR number: 21-192
  • Date: March 2022
  • LC numbers: 32

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd) 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.

The purpose of this intervention was for ONR to determine the adequacy of implementation of Sellafield Ltd’s arrangements for compliance with LC 32 ‘Accumulation of radioactive waste’ at the Thermal Oxide Reprocessing Plant (THORP).

The overall adequacy of Sellafield Ltd's site-wide arrangements for LC 32 are considered separately in other ONR interventions.

Interventions Carried Out by ONR

We, the Site Inspector for THORP and Fuel Storage and a Nuclear Liabilities Regulation (NLR) specialist undertook an inspection against compliance with LC 32 ‘Accumulation of radioactive waste’.

I, the Site Inspector for THORP and Fuel Storage also followed up on a gap from a recent LC 25 ‘Operational records’ compliance inspection at Fuel Storage (ONR-SDFW-IR-21-119, Revision 0). The gap related to records for radioactive waste, which are completed by THORP personnel, and could not be sampled during the LC 25 compliance inspection due to personnel unavailability on the day.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since these were not safety system-based inspections.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

For LC 32, the inspection focused on solid radioactive waste and evidence for the implementation of the Sellafield corporate LC 32 arrangements at THORP, specifically those related to minimisation and records. A number of areas of good practice were observed during the inspection. This included evidence of both minimising the rate of production and total volume of radioactive waste accumulated on THORP, and adequate controls of local records in relation to radioactive waste. The THORP Plant Solid Waste Coordinator (PSWC) was utilising arrangements above and beyond the Sellafield Ltd Corporate requirements for the management of waste (radioactive and non-radioactive, for example chemicals). No regulatory issues were raised as a result of the inspection.

For LC 25, a Service Level Agreement (SLA) between Fuel Storage and THORP was provided during the intervention, and waste records sampled. Both were found to be adequate and no further regulatory action was identified.

For both LC 32 and LC 25 an observation was made that the retention period for the records sampled was inconsistent with the requirements of wider licence conditions (for example LC 6 ‘Documents, records, authorities and certificates’). THORP personnel noted they consider the Sellafield Waste Electronic Tracking and Assessment System (WETAS) to be the formal record of the radioactive waste inventory, however reference to this system was not identified in the record retention schedule sampled (SL_RRS_001, Version 4.1). This intelligence has been shared with the relevant ONR Corporate Inspector for consideration in the Sellafield Ltd Corporate interventions.

Conclusion of Intervention

For LC 32, based upon the evidence sampled for the implementation of the Sellafield corporate LC 32 ‘Accumulation of radioactive waste’ arrangements at THORP, an inspection rating of Green is considered appropriate.

The gap identified in the recent LC 25 compliance inspection on waste records for Fuel Storage is considered closed.