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 in the Magnox Operating Unit (OU) was carried out, as planned, in May 2016.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 32 (Accumulation of waste). The Magnox Reprocessing Facility (MRF) was selected as the target for this inspection because of the potential of the MRF processes to create low and intermediate level waste and the importance of minimising and managing any accumulation of waste.
LC 32 requires the licensee to make and implement adequate arrangements to minimise, so far as is reasonably practicable, the rate of production and volume of radioactive waste, and for the control of such waste, once generated.
On 17 May 2016, I carried out a one-day, on-site LC 32 compliance inspection in the Magnox OU. The inspection comprised discussions with SL staff, a plant walk-down, and reviews of plant records and other documentation. As part of my preparation for the delivery of this intervention, 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 sampled the management of radioactive wastes arising from the operational activities (maintenance, repair, and inspection) within a targeted sample of the plants that comprise the Magnox Reprocessing Facility (MRF). Additionally, I examined activities undertaken by the MRF to ensure that all waste arising from such operational activities was adequately managed, and that sufficient and effective waste management streams existed for all waste generated as a result of MRF operations.
I judged that, on the evidence sampled, the licensee has adequately implemented its site and facility processes to ensure that waste is controlled within the facility, and that the extant site waste streams are utilised in a timely and safe manner. However, I also noted that there were areas of plant where the management of waste was not at a consistent standard, especially in terms of the control of operational lay-down areas. The licensee had already recognised this in advance of my inspection and an improvement plan is being delivered that should address these minor shortfalls.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that, against compliance with Licence Condition 32, an IIS rating of Green (No Formal Action) is merited.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Condition 32 are being implemented adequately.