Office for Nuclear Regulation

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Compliance Inspection of Licence Conditions 7, 11 and 26 at the Waste Treatment Complex and Engineered Drum Stores within the Remediation Directorate, and attendance at Level 4 Regulatory Interface Meetings at the Remediation Directorate and HALES Operating Unit on Sellafield Ltd's nuclear licenced site

Executive summary

Purpose of intervention

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, Decommissioning, Fuel and Waste Programme. In accordance with that Strategy, a Licence Condition compliance inspection of the Remediation Directorate was carried out as identified within the planned inspection schedule for Operational Waste Facilities.

This planned intervention was undertaken to determine if the Waste Treatment Complex (WTC) and Engineered Drums Stores (EDS) are adequately implementing SL's site-wide arrangements for compliance with Licence Conditions 7 (Incidents on the site), 11 (Emergency arrangements) and 26 (Control and supervision of operations). These solid waste handling facilities were chosen because of the radiological hazard associated with their waste inventories.

Interventions Carried Out by ONR

I carried out a one-day, on-site, licence condition compliance inspection of the WTC and EDS, assisted by two ONR nuclear safety inspectors. Following the compliance inspection, over two days, I held a number of routine intelligence gathering meetings.

The inspection comprised discussions with SL staff, a partial plant walk down, and examination of a sample of plant operational and administrative records. The inspections were carried out in accordance with the following formal ONR inspection and assessment guidance:

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A; this was not a System Based Inspection (SBI).

Key Findings, Inspector's Opinions and Reasons for Judgements Made

From the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with LC 7 and I have assigned an inspection rating of Green (No formal action) here.

I observed a number of minor shortfalls associated with the implementation of local SL emergency instructions which did not align to the format required of corporate SL procedures. I did not consider this administrative shortfall to be significant however, since only minor changes to forms rather than significant content are anticipated to correct the matter. However, I have generated a regulatory issue here to track the timely completion of the necessary revisions. Notwithstanding this observation, overall from the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with LC 11, and I have assigned an inspection rating of Green (No formal action) here.

I observed one minor shortfall associated with the justification of Minimum Safety Manning Levels (MSMLs) within the WTC and EDS. I noted that the MSMLs have not been reviewed following the creation of the Remediation Directorate in May 2016. I did not consider this administrative shortfall to be significant however since the hazard, operations and staffing levels within the WTC / EDS have not significantly changed as a result of the creation of the Remediation Directorate. However, as a result of this shortfall, I generated one minor regulatory issue to track the timely completion of the MSML review. Notwithstanding this observation, overall from the evidence sampled during this inspection, I consider that SL has effectively implemented its arrangements for compliance with Licence Condition 26, and I have assigned an inspection rating of Green (No formal action) here.

Conclusion of Intervention

My findings were shared with, and accepted by SL, as part of routine inspection feedback. I have raised two minor Regulatory Issues as a result of this inspection, to ensure the identified administrative shortfalls are effectively remedied.