This intervention was undertaken on 6 – 10 October 2014 at the Sellafield Limited (SL) nuclear licensed site in Cumbria.
Inspection of Licence Condition (LC) compliance at nuclear licensed sites is an important aspect of ONR’s activities. ONR has defined a programme of system inspections and LC compliance inspections, which focus on the aspects of Sellafield Limited’s operations that are most important to safety and legal compliance. This inspection is identified on ONR’s PP3 inspection plan which covers Sellafield Limited’s Decommissioning Division.
I carried out an inspection of the Licensee’s arrangements for compliance with Licence Condition 32 (LC32) in the Decommissioning Division. LC32 requires the licensee to make and implement adequate arrangements for minimising so far as is reasonably practicable, the rate of production and total amount of radioactive waste accumulated on the site at any time and for recording the waste so accumulated. This inspection was carried out in accordance with ONR’s inspection guidance for LC32 as defined in NS-INSP-GD-032.
This inspection focussed on Solid Low Level Waste (LLW) and Solid Intermediate Level Waste (ILW), but excluded the bulk waste contents of the Legacy Ponds and Silos which are subject to other ONR intervention activities. This was considered an important topic for inspection as previous ONR interventions have identified radioactive waste as a potential issue at a number of Decommissioning plants.
The inspection was carried out through office-based examination of procedures and records, physical inspection on the plants and interviews with staff. The intervention was undertaken by the Site Inspector supported by ONR Radioactive Waste Specialist Inspectors and an Environment Agency Nuclear Regulator.
N/A – This was not a Safety Systems inspection.
I judged that the implementation of Plant Solid Waste Coordinators and Waste advisers has had a positive impact on the management of waste on the Decommissioning plants. The working relationships demonstrated between the Plant Solid Waste Coordinators and Waste Advisers were demonstrated to be effective and the individuals in these roles were motivated to address the waste issues on site. Tangible improvements were noted in housekeeping on some of the legacy facilities inspected.
Improvements to the solid LLW management process have been implemented by Sellafield Limited. This was shown to be an effective process for managing routine wastes generated on the plants. Improvements have also reduced the turnaround time for routine waste removal from the plants.
Numerous examples of legacy waste were observed on many plants and more recent wastes stored in temporary laydown areas were observed near to the working plant areas. It was not possible during this inspection to quantify the total amount of waste held across Decommissioning or how much of a barrier this presents to the timely remediation of the major hazards, but this fell short of good practice. An example of where waste was impacting flask transfers from a high hazard plant was observed. I challenged why removal of at least some of this waste is not reasonably practicable to free up space to support the decommissioning programme. Sellafield Limited agreed to review options for improving characterisation and clean-up of this legacy waste and arrangements for waste laydown near to the Decommissioning Plants.
Sellafield Limited demonstrated an improvement in the standard of laydown areas created for the temporary storage of waste awaiting characterisation and disposition, with improved segregation, marking and identification, although this did not appear to have been adhered to in all areas.
The route for Decommissioning ILW was not being used. This appears to be a significant gap in Sellafield Limited’s arrangements. A route had been made available to use an existing ILW store on site, but the acceptance criteria for the waste is restrictive and no Decommissioning waste has been sent there for a number of years. Sellafield Limited agreed to review the ILW waste strategy for Decommissioning and consider how this could be improved.
I inspected the training programme for key roles associated with waste management in Sellafield Limited. I judged the training material and SQEP arrangements for these roles to be of a good standard. However the same level of training was not applied to sub-contractor staff for waste handling. Sellafield Limited is satisfied that its downstream inspection and monitoring regime is adequate to control the waste routes, but agreed to look at how equivalent controls could be extended to contractors to reduce reliance on this monitoring.
The records associated with some legacy wastes are not all readily retrievable. Sellafield Limited believes these may still exist in archives, but will not be easy to locate or reliably associate with the waste packages, so the intention is to fully re-characterise the waste for disposition. Whilst this will add time and effort to the process, as long as this is carried out within a reasonable timeframe I consider this to be a reasonable proposal. The licensee indicated it has included all wastes on the National Radioactive Waste Inventory (RWI), but this would not be at a detail adequate to support future disposition of the waste. Therefore more detailed information may be required
I judged the licensee’s compliance to LC32 to be below standard, principally due to the fact that Sellafield Limited could not demonstrate that it was minimising so far as is reasonably practicable the total amount of radioactive waste accumulated within the Decommissioning Division, and also the records for the waste accumulated appeared inadequate. I do not consider these shortfalls to be an immediate safety concern, but they did not meet ONR’s expectations as defined in our guidance and fall short of relevant good practice.
A number of actions and recommendations were agreed with the licensee, and these will be followed up by ONR as part of normal regulatory interactions with the licensee.
I further recommend that another LC32 inspection, on the provision of safety cases for waste storage, waste records and inspection/maintenance of waste packages is included in next year’s ONR inspection programme for the Decommissioning Division.