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 planned compliance inspection was undertaken in December 2017 at the Active Handling Facility (AHF) against Licence Conditions 4 (LC4, restrictions on nuclear matter on site) and 32 (LC32, accumulation of radioactive waste).
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 4 and LC 32. The Active Handling Facility (AHF) was selected as the target for this inspection because NNL imports and exports a significant number of shipments containing nuclear matter and that, if not controlled adequately, the nuclear matter and the volumes of low and intermediate level wastes generated as a result of operations within AHF on the nuclear matter, could be hazardous to the facility workforce and prevent the AHF supporting the High Hazard and Risk Reduction programme at SL and other nationally important programmes.
LC 4 requires that the licensee ensures that no nuclear matter is brought onto the site or stored on the site except in accordance with adequate arrangements made by the licence for this purpose. 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 5 and 6 December 2017, I carried out a two-day, on-site LC 4 and 32 compliance inspections in the Remediation Directorate in the AHF facility. The AHF facility is leased by SL to NNL. The inspection comprised discussions with SL and NNL staff, a focused plant walk-down and reviews of plant records and other documentation. I was supported on the inspection by a specialist inspector (radioactive waste management and nuclear liabilities) and an ONR graduate under training. A member of SL's independent internal regulation team also participated in the inspection.
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 LC 4 inspection, I sampled documentary evidence that supported bringing nuclear matter onto the SL licenced site and the storage of nuclear matter in the AHF, in a safe and controlled manner.
I noted a number of areas of good practice, particularly in terms of the evidence provided for the control of nuclear matter into and out of the AHF and its on-plant storage and corresponding records. I also noted the knowledge and experience of the key NNL staff and the use of focused and relevant training for some key plant staff.
However, during my documentation review and subsequent discussions, I identified a two of areas where NNL's evidence was significantly below the standard I would expect of a nuclear facility. One relates to limits and conditions and was declared by SL and NNL, at the onset of the inspection. The other relates to a shortfall in training evidence. Whilst I saw no impact on the control of nuclear matter, I judged that, if allowed to remain, these could have a detrimental impact on the licensee's control of nuclear matter in the longer term. I also identified a number of minor shortfalls in NNL requirements documentation, cave inventory location documentation and record retention periodicity.
I have raised a number of ONR Regulatory Issues that will bring the licensee back into compliance with relevant good practice for these observed shortfalls.
During my LC32 inspection, I sampled documentary evidence that supported the management of radioactive wastes arising from operations, maintenance, repair, and inspection in AHF. 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 extant site waste streams are utilised in a timely and safe manner to avoid the accumulation of wastes in AHF. Additionally, the licensee is continuing to address previous shortfalls in their management of legacy wastes and has programmes of work to systematically reduce the volumes of legacy waste held within the facility.
I noted a number of areas of good practice, particularly in terms of on-plant waste stream segregation, 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.
However, I identified a number of shortfalls where AHF performance was below the standard I would expect of a nuclear facility, one of which is significant and is common with my LC4 findings regarding limits and conditions. I also identified some minor shortfalls in managing Zinc Bromide leakages and the accuracy of the cave waste inventory sheets. These may 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 two additional ONR Regulatory Issues that will track the licensee's response to these observed shortfalls.
From those areas sampled, I did not identify any additional significant shortfalls in the licensee's or tenants 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, but I judge that there are several significant shortfalls against identified relevant good practice when compared with appropriate benchmarks. Therefore, it is my opinion that, against compliance with Licence Conditions 4 and 32, an inspection rating of Amber (Seek Improvement) is merited for each Licence Condition.
I consider that the licensee has complied with its legal duties, and, although I believe that there is no significant impact on nuclear safety, I judge that there are several significant shortfalls against identified relevant good practice when compared with appropriate benchmarks. Therefore, it is my opinion that, against compliance with Licence Conditions 4 and 32, an inspection rating of Amber (Seek Improvement) is merited for each Licence Condition.