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, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for the current regulatory year (covering April 2018 - March 2019), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This planned intervention was to determine if SL’s tenant National Nuclear Laboratory (NNL) is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 32 (Accumulation of radioactive waste) within its Central Laboratory facility. NNL Central Laboratory provides a number of important roles (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that also support the safety of Sellafield site-wide operating facilities, including its high hazard and risk reduction work.
The overall adequacy of SL's site-wide LC32 arrangements is considered separately in other ONR inspections.
Licence Condition 32 requires the licensee to make and implement adequate arrangements for minimising so far as is responsibly practicable the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated.
These duties apply to the NNL organisation even though it is a tenant on the Sellafield site.
My inspection, which comprised discussion with SL and NNL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on NNL’s:
Not applicable, this was not a safety system based inspection.
There were no significant findings identified during my inspection, and I have not raised any associated Regulatory Issues. I am of the opinion that SL, as the licensee, provides an adequate level of assurance to its management and control of its tenant.
NNL Central Laboratory organisation demonstrated an adequate understanding of the licensee’s site-wide arrangements. Overall, I consider that NNL has adequately implemented its arrangements for compliance with LC32 within its Central Laboratory organisation. Indeed, this implementation is good in several areas, for example planned introduction of a very low level waste stream; and the use of SL’s subject matter experts to assess NNL’s waste co-ordinators. However, there were also some minor areas for improvement, for example the establishing of designated parking locations for waste drums within its laboratories.
For these reasons, and on balance, I consider that an inspection rating of Green (No formal action) is merited against LC 32 as a result of this inspection.
My findings were shared with and accepted by the licensee and NNL as part of normal inspection feedback. In addition, I have not raised any new Regulatory Issues as a result of this inspection.