Office for Nuclear Regulation

Analytical Services (AS) - ONR compliance inspection of LC 32 and LC 35

Executive summary

Purpose of Intervention

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 Divisions.  In accordance with that strategy, a planned compliance inspection was undertaken in March 2020 at Analytical Services (AS) against Licence Conditions (LC) 32 (Accumulation of Radioactive Waste) and LC 35 (Decommissioning).

The purpose of this inspection was to seek assurance that SL’s arrangements for compliance with LC 32 and LC 35 were adequately implemented at AS and complied with the relevant expectations of ONR.

Interventions Carried Out by ONR

On 3rd and 4th March 2020, I carried out a compliance inspection against LC 32 and LC 35 at AS.  The inspection comprised discussions with SL staff, reviews of plant records and other documentation and a plant inspection.  I was supported by a Nuclear Liabilities Regulation (NLR) Specialist Inspector and a Nuclear Associate from the Nuclear Internal Hazard and Site Safety (NIHSS) Specialism.  The Inspection was also supported by the relevant Environment Agency (EA) Site Inspector and a member of SL’s Nuclear Intelligence and Independent Oversight (NI&IO) compliance team.

The primary requirement of LC 32 is for the licensee to make and implement adequate arrangements to minimise, so far as is reasonably practicable, the rate of production and total amount of radioactive waste accumulated, and to record the waste so accumulated.

The primary requirement of LC 35 is for the licensee to make and implement adequate arrangements for the decommissioning of any plant or process that may affect safety, including arrangements for the production and implementation of decommissioning programmes.

Given the central role of AS at SL, and upcoming challenges for SL’s analytical capability (e.g. retrievals from the Legacy Ponds and Silos and closure of the era of reprocessing), the inspection team also considered the adequacy of cross-site integration between AS and inter-dependent facilities insofar as this contributes to SL’s broader compliance with LC32 and LC35.

As preparation for this intervention, the following ONR technical inspection guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a System Based Inspection, therefore no judgement was made of the adequacy of implementation of any part of the safety case.

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

During the LC 32 inspection, I sampled documentary evidence relating to the licensee’s strategy, plans, resources and inventory in respect of radioactive waste including relevant ongoing work against extant Regulatory Issues and outcomes from the most recent Long Term Periodic Review (LTPR).

The licensee conveyed the main challenges in the scope of its current work and potential impacts from the reduction in waste routes that will occur when Magnox Reprocessing Facility (MRF) closes around the end of 2020. I sought assurance the licensee was adequately considering the likely changes in demands upon AS from donor facilities, as the site’s reprocessing infrastructure transitions into Post Operational Clean Out (POCO). 

I observed that following previous interactions, the licensee has greatly improved its understanding of the status of its radioactive waste and made considerable progress in disposing of the legacy wastes of greatest risk to safety, with the priority being non-robust bottles of legacy solvent.

There remains a lack of strategic planning to drive forward the timely disposal of the remainder of the current inventory. I have therefore raised a Level 4 Regulatory Issue to ensure the licensee develops a comprehensive strategy and plan to resolve remaining uncertainties in its inventory and minimise accumulations of radioactive wastes so far as is reasonably practicable.

I undertook a plant inspection to sample those areas that had accumulated legacy waste at the facility, and to establish if the licensee is adequately managing the accumulation and safe storage of their radioactive wastes.   

During the LC 35 inspection, I sampled documentary evidence relating to progress with preparation for POCO activities, the declared start date for which in AS is 2030 (associated with the transfer of remaining analytical work to NNL).

I also observed that the licensee had already decommissioned some labs, several glove-boxes (GBs) were quoted as having already undergone POCO and further decommissioning projects are planned for completion before 2030.  I therefore checked that the licensee recognised the importance of ensuring these projects are taking place in accordance with SL’s corporate POCO and decommissioning arrangements and strategies.  I also checked the licensee has adequately engaged with the relevant enterprise-level functions such as the Central POCO Group and Problematic Waste Team.

I noted worthwhile recent improvements to the standard of asset care at AS facility, such as to the ventilation ductwork, replacement of obsolescent instrumentation and the civil structure.

The licensee reported some significant challenges that had been faced in the decommissioning work already undertaken within AS such as constraints in space, vulnerable containment systems and the fitness-for-purpose of ventilation supplies. I advised the licensee to capture the lessons learned and ensure this LFE is applied so far as is reasonably practicable to its next generation of analytical labs in order to deliver the benefits of ‘design for decommissioning’.

It was evident the licensee had not progressed the majority of recommendations from a POCO strategy document it produced in 2015 regarding several types of legacy waste.  Some of the currently available routes for management of these wastes will be foreclosed as the era of reprocessing comes to an end.  I therefore raised a Level 4 RI for the licensee to review the recommendations in its strategy document and provide a programme to deliver progress or adequately justify the current position. 

Conclusion of Intervention

Based on the sample inspected and the associated evidence gathered before and during this intervention, I do not consider there to be any matters that have the potential to impact significantly on nuclear safety.  As a result, I have rated the inspection as GREEN – no formal action against both LC32 and LC35.

I consider that no additional regulatory intervention is needed over and above those already planned for AS at SL, as set out in the Integrated Intervention Strategy by ONR’s Sellafield Sub Divisions.  I have raised 2 Level 4 Regulatory Issues (RI), one against each of LC32 and LC35 respectively, to monitor progress against the minor shortfalls identified.