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. The planned inspection schedule 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.
Licence Condition 35 (LC35, Decommissioning) requires the licensee to make and implement adequate arrangements for the decommissioning of any plant or process which may affect safety. This planned intervention was led by ONR and supported by the Environment Agency to determine if the Decommissioning Division is adequately implementing SL’s site-wide arrangements for compliance with LC35.
Decommissioning Division includes all the legacy ponds and silos (LP&S), which present some of the largest radiological risks to workers and public at Sellafield and to the UK. The effective and efficient decommissioning of these buildings is a major component of the delivery of the Sellafield high hazard and risk reduction programme. In addition, these buildings, which comprise a number of open-air ponds and storage silos, contain a significant inventory of legacy radioactive wastes which are subject to a retrieval, storage and disposal programme under the regulatory oversight of ONR and EA. The adequacy of these plant’s decommissioning arrangements is therefore important to ensuring nuclear safety on the licensed site.
I, accompanied by a specialist inspector in decommissioning and radioactive waste management carried out an inspection comprising discussions with SL staff and examination of site, Divisional, programme and facility documentation. We also undertook a specific inspection of how this documentation has been applied to a specific facility, the Pile Fuel Storage Pond (PFSP), as a sample of the LP&S facilities. The inspection focussed on the following areas:
Not applicable; this was not a Safety System inspection.
The team considers that the implementation of the site’s arrangements for LC 35 is good in a number of areas. For instance, there was evidence of good progress in relation to the production of a Decommissioning Strategy, Decommissioning and Remediation Manual and POCO arrangements. I noted demonstrable progress in the adoption of a decommissioning mind-set and the use of fit for purpose safety cases and approaches to decommissioning.
This progress is however, offset by shortfalls we found in the completeness of SL’s arrangements that support its Decommissioning and Remediation Manual, most notably the absence of a procedure requiring the production of decommissioning programmes and/or plans. It was thus not possible for Decommissioning Division to demonstrate full compliance with the requirements of LC35. The absence of a procedure is however not preventing SL from producing decommissioning programmes and plans; rather, it is leading to variations in their scope and detail. In other words, though fundamental requirements are being met, SL’s arrangements have procedural weaknesses requiring improvement. For these reasons, I have awarded an IIS rating of 4 (Below Standard) against LC35.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I have raised a Level 3 Regulatory Issue as a result of this inspection to address the shortfall identified.