Office for Nuclear Regulation

Sellafield – Licence Condition 32 and 33 Corporate arrangements inspection

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.  In accordance with this strategy, a Licence Condition (LC) 32 (Accumulation of radioactive waste) and 33 (Disposal of radioactive waste) arrangements inspection was carried out, as planned, on 30 October – 1 November 2018.  The purpose of the inspection was to determine whether SL’s arrangements are adequate to ensure the site’s compliance with LC32 and 33.  The inspection drew intelligence from other ONR inspections and assessments which examine the implementation of the site-wide arrangements in operating facilities.

Interventions Carried Out by ONR

The inspection was carried out by ONR’s Corporate Inspector and two Nuclear Liabilities Regulation specialist inspectors.  SL’s internal regulator, the Nuclear Independent Oversight (NIO) team, also participated.

The inspection focussed on the following areas:

ONR’s technical inspection guides NS-INSP-GD-032 and NS-INSP-GD-033, as well as the technical assessment guide NS-TAST-GD-024 formed the basis for the inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable as this was not a system based inspection.

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

SL has developed a set of arrangements for compliance with LC32 and 33 which generally meet relevant good practice.  Accountability for implementation rests largely with waste generators but is supported by a network of waste advisors and coordinators and a technical team which sits within the Remediation value stream.

I found a number of good practices in SL’s arrangements, including:

I observed one minor shortfall in SL’s arrangements, namely insufficient recognition in the solid / aqueous / gaseous waste management manuals and role specifications of the full scope of site licence conditions and other legislative requirements for management of radioactive waste on a licensed site.  This shortfall was acknowledged by SL.  ONR has an existing regulatory issue (RI 5644) which it will modify by the addition of a new action, to track SL’s progress in addressing the shortfall.

During the course of this inspection I also observed several instances of failure to implement SL’s standard for on-site temporary storage of radioactive wastes.  This shortfall was acknowledged by SL.  ONR has an existing regulatory issue (RI 6780) which will be scoped to track SL’s progress in addressing the shortfall.

Through this inspection I have also requested clarification from SL on its interpretation of the Nuclear Decommissioning Authority’s definition of problematic waste, in particular its understanding of ‘sub-optimal’ waste management.

Conclusion of Intervention

I consider that the licensee’s arrangements are adequate to ensure the site’s compliance with LC32 and 33 with one minor shortfall which will be addressed by modifying an existing Level 4 regulatory issue.  It is my opinion that that an inspection rating of ‘Green’ (no formal action) is merited.