Office for Nuclear Regulation

Sellafield Retrievals (PP3) - First Generation Magnox Storage Pond (FGMSP) - inspection of LC 35

Executive summary

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, Licence Condition (LC) compliance inspections were carried out on the Retrievals Value Stream, as planned, in October 2019.

The purpose of this planned inspection was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with Licence Condition (LC) 35 (Decommissioning).  Sellafield Limited’s (SL’s) First Generation Magnox Storage Pond (FGMSP) was selected as the target for this inspection because of its progress with waste retrieval compared with other high hazard risk reduction facilities.

Interventions Carried Out by ONR

LC35 requires the licensee to “make and implement adequate arrangements for the decommissioning of any plant or process that may affect safety”.  On 9 October 2019, I, along with the Remediation Site Inspector, carried out a planned licence condition compliance inspection of the FGMSP facility.  The inspection comprised discussions with SL staff and reviews of plant records and other documentation.

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 LC35 inspection, I undertook a review of the relevant Sellafield procedures against the ONR guidance document for LC35, NS-INSP-GD-035 Revision 5.  From the areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC35 which would prompt an inspection of these arrangements earlier than currently planned.

In order to judge the adequacy of the implementation of these arrangements, I targeted plans for future decommissioning, progress with retrievals and knowledge management for decommissioning.  From the sample I reviewed, I judged that the licensee is making good progress with retrievals.  However, I found that the licensee’s arrangements for the review of decommissioning plans could benefit from improvement; without an adequate procedure, I consider that there may be challenges associated with demonstrating completeness and consistency.  The licensee agreed that there would be benefit in revising the arrangements, and I have raised a regulatory issue to oversee progress with this minor shortfall.

Additionally, I found some instances where the licensee fell short of expectations in relation to knowledge management for decommissioning.  Whilst I consider the individual instances to be minor, together they reduced confidence that data and information obtained and recorded now will be accessible in the future to support safety in decommissioning.  The licensee clearly recognised the challenges associated with managing knowledge in the long term, but agreed with my observations and committed to providing assurance that effective knowledge management for decommissioning is being undertaken at FGMSP.  I have raised a regulatory issue to oversee progress with this minor shortfall.

Notwithstanding this, on the basis of the evidence sampled at the time of this inspection, I judged that the licensee has adequately implemented its arrangements for compliance with LC35 (decommissioning).  I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.

Conclusion of Intervention

From the evidence gathered during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety.

At present, no additional regulatory action is needed over and above the planned interventions within the Retrievals Value Stream at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.