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 Programme.
In accordance with that strategy, a Licence Condition (LC) compliance inspection of the Solid Waste Operating Unit was carried out as planned in August 2015. The purpose of this inspection was for the ONR to confirm the adequacy of implementation of the licensee’s formal arrangements for compliance with the selected LCs detailed below. This facility was identified for inspection due to the hazardous nature of the plutonium contaminated material (PCM) that the facility processes.
On 19-20th August 2015, I carried out a two-day, on-site LC26 and LC32 compliance inspection of the Solid Waste OU. The inspection comprised discussions with SL staff and reviews of plant records and other documentation
LC26 requires SL to ensure that all operations that affect safety are undertaken under the control and supervision of suitably qualified and experienced persons who have been appointed for that purpose.
LC32 requires SL to have adequate formal arrangements to minimise, where practicable, the rate of production and total quantity of radioactive waste stored on site.
As part of the preparation for delivery of these interventions, the following formal ONR guidance documentation was used:
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.
During my inspection, I examined the quality of shift supervision within the Waste Treatment Complex (WTC); this is the facility within which PCM is processed to reduce its hazards prior to longer-term storage on the site.
From the evidence gathered, I judged that supervision was adequate, and that it was capable of promptly recognising and delivering short term changes in the level of operational oversight and support required. In addition, I examined evidence sampled in support of potentially hazardous maintenance tasks undertaken within one of the Engineered Drum Stores (EDS); the facilities for the storage of PCM waste on the site. It was my opinion that this sample indicated that the level of supervision in place has been appropriate to deliver suitable control of the risks presented by that task. Therefore, I judge that an IIS rating of 3 (Adequate) is merited for the implementation of the licensee’s arrangements for compliance with Licence Condition 26.
With regard to LC32, I inspected evidence relating to the licensee’s management of PCM waste across the whole site. In my opinion, whilst the licensee has started to consider systemically the management of PCM waste, it has yet to complete sufficient work to support appropriate decisions for the management of that waste.
The licensee has made reasonable progress in identifying options for the effective storage and pace of treatment of PCM on the site, although SL still has much work to complete before any of these options have an impact on site. Therefore, it is my opinion that an IIS rating of 3 (Adequate) is merited for the implementation of the licensee’s arrangements for compliance with Licence Condition 32.
Within both compliance inspections, I have made a number of regulatory observations, all of which have been accepted by the licensee, and which are summarised within this Intervention Record. Additionally, during each inspection, I have identified what improvements, if undertaken by the licensee, could attract a higher IIS rating at future relevant LC compliance inspection(s).
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the formal arrangements for Licence Conditions 26 and 32 are being implemented adequately.
As part of the LC 32 compliance inspection, I identified additional information that informs an extant ONR Regulatory Issue regarding the management of PCM at the Sellafield site [RI 1981]. The RI has now been updated, reflecting the continued adequacy of site progress against PCM hazard reduction.