Office for Nuclear Regulation

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Analytical services re LCs 32 and 34

Executive summary

Purpose of intervention

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 Programme. My planned inspection schedule for the current regulatory year (covering April 2014 – March 2015), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period. 

This intervention was undertaken to determine if the Analytical Services (AS) facility is adequately implementing SL’s site-wide arrangements for compliance with Licence Conditions 32 and 34.  AS was selected for this inspection because of the significant radioactive inventory held and processed within the facility, as well as the age of the facility.

Interventions Carried Out by ONR

Licence Condition 32 (LC32) requires the licensee to make and implement adequate arrangements for minimising, so far as is reasonably 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.

My inspection, which comprised discussions with SL staff, and examination of plant documentation, focussed on the following areas:

Licence Condition 34 (LC34) requires the licensee to ensure, so far as is reasonably practicable, that radioactive material and radioactive waste on the site is at all times adequately controlled or contained so that it cannot leak or otherwise escape from such control or containment.

My inspection, which comprised discussions with SL staff, examination of plant documentation, and physical inspection of the facility, focussed on the following areas:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

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

I consider that the licensee has effectively implemented its arrangements for compliance with LC32.  There were a number of areas of good practice, and a number of improvements that could reasonably be made, all of which were accepted by the licensee.

I consider the facility’s implementation of the site’s arrangements for LC32 is good in many areas.  For instance there is a clear recognition of the benefit of reducing sample volumes and progress is being made to this end. There is also good and proactive work being undertaken to reduce legacy waste stored in the facility. This is however offset by the lack of a SQEP (Suitably Qualified and Experienced Person) training package for the role of waste coordinator, and a lack of formality in a number of processes described. For these reasons, on balance, I consider the inspection merits an IIS rating of 3 (Adequate), against LC32.

I identified a small number of minor shortfalls in the licensee’s implementation of their LC32 arrangements.  Having reviewed these, I am content that none present any safety concern.  

I consider that the licensee has implemented effectively a number of measures to improve compliance with LC34.  I noted a number of areas of good practice, but also a number of improvements that could reasonably be made, which were accepted by the licensee.

However, although fundamental requirements were met, SL could not provide a coherent narrative regarding the status of the cracks in the facility’s civil structure. I consider this a significant shortfall and as such have awarded an IIS rating of 4, (Below Standard), against LC34. That said, I do not consider the cracks to present any immediate safety concern and I will progress this matter as part of an existing ONR Regulatory Issue related to the age of this facility.

Conclusion of Intervention

My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. No new ONR Regulatory Issues were raised as a result of this inspection.