The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule for the current regulatory year (covering April 2014 – March 2015), the content of which is guided by that strategy, defines the Licence Conditions (LC) that will be inspected over this period.
This intervention was undertaken to determine if the Waste Treatment Complex (WTC) area is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 32. I selected this combination of facility and licence condition to provide me with evidence of the licensee’s management of Plutonium Contaminated Material (PCM) at site, given that there is an extant Licence Instrument (LI326) which requires that 90% of all site holdings of PCM generated prior to 2000 are to be placed in a passive state by 2020.
The licensee has previously stated that they would not be able to meet the requirements of LI326, but that there were a number of safety related activities that would be achieved, and that these would be monitored and reported to ONR. In correspondence between ONR and the licensee, this position has previously been accepted by the regulator. Evidence from this inspection will contribute to any future review of the regulatory value of LI326.
Licence Condition 32 (LC32) requires the licensee to make and implement adequate arrangements for the minimisation, so far as is reasonably practicable, the rate of production and quantity of waste accumulated on the site. My inspection, which comprised discussions with SL staff and examination of plant documentation, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I judge, from the evidence presented, that the site-wide arrangements for compliance with LC32 have been implemented appropriately within the WTC facility; all the evidence I sampled demonstrated that the facility was undertaking waste control operations in accordance with these arrangements. It is my opinion that in WTC compliance with LC32 is adequate.
I consider that the facility is undertaking effective forecasting of future PCM waste volumes, and that this activity is having a benefit in both the short term (operational planning), and long term (strategic management of facilities). I noted, and the licensee agreed, that the extent of the benefit was dependent on the accuracy of the waste estimates received from across the site.
The WTC facility is, over the next 18 months, improving its capability to review the characterisation of PCM waste. I consider that this enhanced capability has both an operational and safety benefit, and I will track progress and implementation of this project through my planned regular engagement with the WTC facility lead team.
The licensee has adequately implemented the arrangements for compliance with LC32. Given that there were some areas of good practice, but also improvements that could be made, I have recorded an IIS rating of 3 (adequate) against Licence Condition 32 (accumulation of waste).
My observations were shared with, and accepted by, the licensee as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.