The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule PP5 for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
I undertook this planned inspection by meeting with facility representatives from the Waste Vitrification Plant (WVP). This facility was selected for inspection since it vitrifies Highly Active Liquor (HAL), thus immobilising the most hazardous by-product of fuel reprocessing. Poor management of waste arising from this process could have a detrimental impact on the pace and sustainability of vitrification, and thus the rate at which this key high hazard reduction occurs at site.
Given that the focus of this inspection (WVP facility) is central to the reduction of HAL stocks at site, I consider that effective management of waste within the facility is central to the achievement of sustainable vitrification operations, which is a key contribution to the ONR Sellafield Strategy. Specifically, therefore, the inspection focused on the management of Medium Active (MA) and Higher Active (HA) wastes within the facility, as they have the greatest impact on the rate and quality of the vitrification process.
The purpose of Licence Condition 32 (LC32) is to ensure that the rate of production (and total quantity) of radioactive waste accumulated on the site is minimised so far as is reasonably practicable.
To judge the extent of compliance with LC32, I carried out a one-day planned inspection, with support from a specialist inspector in radioactive waste management. Additionally, as part of the working relationship between the external regulators, this inspection was a joint inspection between ONR and the Environment Agency (EA); the inspection team was augmented by the EA regulator with responsibility for the WVP facility.
The inspection comprised a number of office-based interviews, involving facility staff, and a walk-down of the specific areas of plant that manage the accumulation and export of MA wastes from the facility to other parts of the licensed site.
Not applicable; this was not a Safety System inspection.
I consider that SL’s arrangements for compliance with LC32 have been effectively implemented within WVP. I identified some minor improvements that could be made, all of which were accepted by the licensee.
I note that the licensee has completed significant work to regain effective control of MA waste arising from the facility, both in terms of minimising the rate of accumulation, and of reducing the detrimental impact on the rate of vitrification within the facility. Whilst these efforts are of a scope that (once completed) I would consider sufficient, the licensee has only just started to deliver changes in the related engineered systems.
Sustaining the initial pace of these improvements will require regular and consistent management focus; I judged that the licensee would need to consider where and how they should formalise their own targets for facility performance in the medium term, and how they define the role of key management personnel in the delivery of that expectation. Pleasingly, recent evidence from the licensee indicates that effective management oversight within the facility can deliver elevated performance in both waste minimisation and reduced rate of accumulation.
For these reasons, on balance, I consider the inspection findings merit an IIS rating of 3 (adequate) against LC32. This is consistent with the IIS ratings guidance, for which the relevant extract is:
“…Arrangements meet guidance requirements. Some opportunities for improvement under ALARP. Areas for improvement known, but being addressed only slowly. Site inspector able to identify minor points for improvement.”
My findings were shared with, and accepted by, the dutyholders as part of normal inspection feedback. I have one extant ONR Regulatory Issue that I have now updated to reflect th findings of this inspection.