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 sub-Division. In accordance with that strategy, I carried out a planned unannounced Licence Condition (LC) compliance inspection in the Magnox Operating Unit (OU) in May 2017.
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, if not controlled adequately, the volumes of low and intermediate level wastes generated as a result of reprocessing operations could be hazardous to the facility workforce.
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 24 May 2017, I carried out a one-day, on-site LC 32 compliance inspection in the Magnox OU. The inspection comprised discussions with SL staff, a full 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 documentary evidence that supported the management of radioactive wastes arising from maintenance, repair, and inspection. Additionally, I undertook a full plant walk down to confirm the extent of accumulated wastes on plant, and to establish if the licensee is adequately managing the accumulation, safe storage and subsequent disposal of such waste within appropriate site radioactive waste streams.
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. Additionally, since my last inspection (May 2016), the licensee has addressed previous shortfalls in their control of operational lay-down areas, which has also started to increase the understanding of plant operational staff in respect of their duties for safe control of waste on plant.
I noted a number of areas of improvement since my last inspection, particularly in terms of on-plant waste stream segregation and related operational marking, the level of engagement between the waste co-ordination team and the operational teams, and the use of focused and relevant on-job training for key plant staff. Many of these improvements are due to the sustained and proactive efforts of the facility waste manager; further performance improvements are dependent on sustained management support in respect of that effort.
However, during my plant walk down, I identified a number of areas of plant where operational husbandry was below the standard I would expect of a nuclear facility, which could potentially have impacted on the licensee’s ability to manage the accumulation of waste effectively. Whilst I saw no such impact manifested, I judged that this condition, if allowed to remain, could have a detrimental impact on the licensee’s control of operational waste in the longer term. Therefore, I have raised an ONR Regulatory Issue that will track the licensee’s response to this observed shortfall.
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 inspection 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.