Executive summary
Date(s) of inspection: April 2024
Aim of inspection
To gain assurance that Spent Fuel Services (SFS) is compliant with Sellafield Ltd’s arrangements for Licence Condition 32 (Accumulation of radioactive waste). The inspection was conducted jointly with the Environment Agency given the common expectations between LC 32(1) and the Radioactive Substances Regulation (RSR) Environmental Permitting Regulations (EPR).
Subject(s) of inspection
- LC32 - Accumulation of radioactive waste - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
I undertook an inspection of Spent Fuel Services’ (SFS) implementation of the Sellafield Site arrangements for LC32 (Accumulation of radioactive waste) in the Fuel Storage (North) area at the Sellafield Ltd Site. The inspection was completed jointly with the Environment Agency who undertook its assessment of compliance with the relevant RSR EPR Permit conditions relating to solid waste management. The Environment Agency will issue its own report on the inspection. The inspection sampled radioactive waste management activities at facilities associated with the Advanced Gas-cooled Reactor Storage Pond (AGRSP) and First Generation Oxide Fuel Storage Pond (FGOFSP).Through sampling of arrangements, discussion with personnel and plant visits, I found that Sellafield Ltd was able to provide evidence of the following:
- Low quantities of operational radioactive waste are generated and stored on both AGRSP and FGOFSP.
- Adequate storage arrangements (capacity and signage) are available for operational radioactive waste accumulations within the areas sampled.
- There are several legacy waste items being stored on the facilities. These are stored externally within the Separations (SEP) area of the site, in dedicated laydown areas, with access controls in place. Externally stored waste items were observed to be suitably covered.
- Training records identified that an adequate number of operational and maintenance staff had completed mandatory waste training requirements.
Sellafield Ltd self-identified shortfalls in meeting the full requirements of its arrangements for a minor quantity of legacy radioactive waste items, specifically related to the provision of unique identifiers for each of the items and gaps within the up-to-date dose rate information within the inventory records. Noting the inventory information available on the scope and nature of the radioactive waste stored, I was satisfied that there is no immediate safety shortfall presented by the type, location and condition of the radioactive waste stored. However, given the absence of a plan to address the shortfalls in the inventory data I have raised a Level 4 (lowest level) regulatory issue to ensure a plan is produced and implemented.
During the inspection, Sellafield Ltd provided an update on progress in addressing accumulation of radioactive waste shortfalls from the previous LC32 inspection, as captured within a Level 3 regulatory issue. Although the waste remains, I am satisfied that Sellafield is progressing its plan to remove this waste.
During the plant walkdown I raised minor observations related to housekeeping and radioactive waste related operator aids, but judged no further regulatory action was required. I also provided regulatory advice related to minor quantities of potentially asbestos contaminated waste stored, ahead of disposal, in AGRSP, related to the Control of Asbestos Regulations 2012. The shortfall has now been addressed.
Notwithstanding the regulatory issue raised, I am satisfied that Sellafield Ltd is compliant with the requirements of LC32 at Fuel Storage (North) and that the inspection merits a Green rating.
Conclusion
Overall, based upon the sample during the inspection I was satisfied that the SFS: Fuel Storage (North) is adequately implementing the Sellafield Ltd LC32 (Accumulation of radioactive waste) arrangements. I am, therefore, content to rate LC32 as Green (no formal action). A single Level 4 (lowest level) regulatory issue has been raised from this inspection in relation to Sellafield Ltd defining and implementing a plan to address shortfalls in inventory data records. The Senior Operational Support Manager accepted my findings at the wash-up.