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 compliance inspection was undertaken, in October 2015 on the Sellafield nuclear site at Sellafield in Cumbria, of the Decommissioning Operating Unit, focusing on the Magnox Swarf Storage Silos (MSSS) and First Generation Magnox Storage Pond (FGMSP), against Licence Condition 6 (LC6, Documents, records, authorities and certificates). The purpose of the inspection was for the ONR to determine the adequacy of SL’s compliance with this Licence Condition.
MSSS and FGMSP were selected because they are high hazard facilities which store large quantities of radioactive wastes. Both are progressing towards retrieval of these wastes, following long periods of storage. These wastes will be retrieved, packaged as appropriate, and stored safely elsewhere on the Sellafield site pending disposal in the proposed national Geological Disposal Facility (GDF). It is important that SL has an adequate management system for the records of wastes in these facilities, which takes account of current storage, planned waste retrieval and subsequent storage elsewhere, and the requirements for management of radioactive waste records over long time periods.
My inspection was carried out over one day, comprising discussions with key SL staff and a review of relevant documentation. The ONR inspection team comprised the ONR Decommissioning Site Inspector and an ONR Specialist Inspector in radioactive waste and decommissioning (Nuclear Liabilities Regulation, NLR). The inspection was attended by a member of SL’s independent internal regulation team.
LC6 requires SL to make adequate records to demonstrate compliance with any of the conditions attached to a nuclear site licence. For the purpose of this inspection, we focused on those records required to demonstrate compliance with Licence Condition 32 (LC32). LC32 requires SLSL to minimise, so far as is reasonably practicable, the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated.
This was not a System Based Inspection (SBI), therefore no such judgement was required.
We inspected SL’s compliance with the arrangements for the management of records for the radioactive wastes in MSSS and FGMSP, taking account of the regulatory expectations set out in ONR’s Technical Assessment Guide for Licensee management of records (NS-TAST-GD-033 Revision 3). It is my opinion that the evidence examined during this inspection did not meet these expectations. An important aspect of LC6 compliance is the production of Record Schedules by the licensee. These should identify what the licensee needs to do with records, for example: record types; retention times; storage and in the case of SL, whether a record is defined as “vital”. SL’s arrangements define radioactive waste records as “vital records”.
We inspected the Records Schedules for both FGMSP and MSSS. The Schedules did not include records for the radioactive wastes accumulated but did include records for wastes that have been disposed of from FGMSP and MSSS. The exclusion of records for accumulated wastes is a significant shortfall, which makes it difficult for SL to demonstrate compliance with LC32 or that vital records are being managed appropriately for these high hazard facilities.
SL provided information on the records generated when radioactive wastes are produced in the facilities (primarily from FGMSP). It became apparent to me that there is no Quality Assurance check or peer review when data is entered into SL’s Waste Tracking database, using the forms for waste packages completed by consignors, such as FGMSP and MSSS. Consequently, it was my opinion that there is potential for the information in the Waste Tracking database to be incorrect. This database is used to make decisions on waste routing, so this shortfall is significant and is one which may occur in other operating units because the same database is used across the Sellafield site.
From the evidence sampled during this inspection, it is my opinion that an IIS rating of 4 (below standard) is warranted for compliance against LC6. This because of the shortfalls identified relating to the exclusion of records of accumulated wastes in facility Record Schedules in MSSS and FGMSP, the lack of robustness of the arrangements for management of the waste database in FGMSP and the lack of assurance for data entered into SL’s Waste Tracking database.I judge it to be important that the records management arrangements shortfalls are corrected before MSSS and FGMSP enter full scale waste retrieval operations where prompt and accurate records of wastes will be required to meet on-site conditions for acceptance for storage and conditions relating to planned disposals, particularly for HAW. A Regulatory Issue will be raised to ensure that the shortfalls identified are addressed by SL in a timely manner.