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, Licence Condition (LC) compliance inspections were carried out on the Operational Waste Facilities Operating Unit (OU), as planned, in August 2018.
The purpose of this planned inspection was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with Licence Condition (LC) 35 (Decommissioning). SL’s Highly Active Liquor Evaporation and Storage (HALES) facility was selected as the target for this inspection because the facility is due to enter into a period of Post-Operation Clean Out (POCO) in 2020 and is planning some related activities earlier, in 2019. POCO is a key enabler for safe plant decommissioning and forms part of SL’s arrangements for compliance with LC35.
LC35 requires the licensee to “make and implement adequate arrangements for the decommissioning of any plant or process that may affect safety”. On 22 August 2018, I, along with the OWF Site Inspector, carried out a planned licence condition compliance inspection of the HALES facility. The inspection comprised discussions with SL staff and reviews of plant records and other documentation.
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.
Prior to the LC35 inspection, I undertook a review of the relevant Sellafield procedure against the ONR guidance document for LC35 (NS-INSP-GD-035 Revision 4). From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC35 which would prompt an inspection of these arrangements earlier than currently planned.
In order to judge the adequacy of the implementation of these arrangements, I targeted progress of POCO preparations. I was satisfied that the licensee is making progress; however, I found that the facility would benefit from making improvements relating to the documentation of activities and decisions to demonstrate such progress. I judge this to be a minor shortfall and have raised a regulatory issue to oversee progress.
I found that the licensee was unable to provide adequate justification for current resource deployment that means that POCO preparations are at risk. I judge this to be a minor shortfall and have raised a regulatory issue to oversee progress.
Notwithstanding this, on the basis of the evidence sampled at the time of this inspection, I judged that the licensee has adequately implemented its arrangements for compliance with LC35 (decommissioning). I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.
From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety.
At present, no additional regulatory action is needed over and above the planned interventions within the Operational Waste Facilities Operating Unit at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.