Office for Nuclear Regulation

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Special Nuclear Materials (SNM) - Compliance inspection of Licence Conditions 32 and 35

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 Sub Division.  In accordance with that strategy, compliance inspections were undertaken in February 2020 in the Special Nuclear Materials (SNM) value stream against Licence Conditions (LC) 32 (accumulation of radioactive waste) and LC 35 (decommissioning).  The LC 32 inspection was limited to SNM North (N).  The LC 35 inspection covered both SNM(N) and SNM South (S).

The purpose of this planned inspection was for ONR to determine the adequacy of SNM’s implementation of the licensee’s formal arrangements for compliance with LC 32 and LC 35.

Interventions Carried Out by ONR

On 4 and 5 February 2020, I carried out two one-day licence condition compliance inspections of the SNM facilities.  The inspections comprised discussions with SL staff, reviews of plant records and other documentation, and a plant inspection (LC32 only).  I was supported by the SNM Site Inspector and another Nuclear Liabilities Regulation (NLR) specialist inspector.  The LC 32 inspection was undertaken jointly with the Environment Agency (EA).  Members of SL’s Nuclear Intelligence and Independent Oversight (NI&IO) team also participated in the inspections.

LC 32 requires the licensee to make and implement adequate arrangements to minimise, so far as is reasonably practicable, the rate of production and total amount of radioactive waste accumulated, and for recording the waste.

LC 35 requires the licensee to make and implement adequate arrangements for the decommissioning of any plant or process that may affect safety, and to make arrangements for the production and implementation of decommissioning programmes.

As part of my preparation for the delivery of this intervention, the following ONR technical inspection guidance documentation was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

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.

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

Prior to the inspection, I undertook a review of the relevant Sellafield procedures against the ONR guidance documents for LC 32 and LC 35.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with the licence conditions that would prompt an inspection of these arrangements earlier than currently planned.

During my LC 32 inspection, I sampled documentary evidence relating to the storage and recording of accumulations of waste.  I observed that the licensee has a good understanding of the arrangements for the management of waste.  Additionally, I undertook a plant inspection to confirm the extent of accumulated waste on plant, and to establish if the licensee is adequately managing the accumulation and safe storage for onward processing on site and eventual disposal.  The licensee conveyed the challenges in managing number and scope of ongoing activities that lead to avoidable waste arisings and has initiated development of local arrangements to better manage the control of non-radioactive waste brought onto plant.

During my LC 35 inspection, I sampled documentary evidence relating to progress with preparation and delivery of Post Operational Clean Out (POCO) activities.  I observed that the licensee has a good understanding of the arrangements for POCO and how they can be applied proportionately, dependent on the size and complexity of the facility.  The licensee has recognised the need to develop adequate decommissioning plans commensurate with the stage in the facility’s lifecycle.

Conclusion of Intervention

On the basis of the evidence gathered during the inspections, I judge that inspections ratings of GREEN (No Formal Action) are appropriate for compliance against both LCs.  This is because I found SL to have adequately implemented its corporate arrangements for these LCs.  Minor areas for improvement will be taken forward via two Level 4 Regulatory Issues; one to monitor progress with improvements for the control of non-radioactive materials brought onto plant, and the second to ensure the licensee has adequate decommissioning plans in place.