Office for Nuclear Regulation

Planned compliance inspection of LC 32, 33, 34 and 35 and reactive unplanned inspection of LC15

Executive summary

Purpose of Intervention

This inspection on the Inutec Ltd licensed site was part of a programme of planned inspections as outlined the Inutec Ltd inspection plan for 2019/20.  The scope of the inspection is aligned to the ONR Decommissioning, Fuel and Waste sub-division strategy and focussed on the effective management of radioactive waste and decommissioning.  The inspection was carried out jointly with the Environment Agency.

Interventions Carried Out by ONR

During this inspection, I examined the arrangements made under Licence Conditions (LCs): LC 32, 33, 34 & 35 related to radioactive waste management and decommissioning.

I also conducted a reactive unplanned inspection of LC 15 Periodic Review.

I sought to gain evidence that:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable.

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

I found that the licensee was able to demonstrate compliance through its procedures and written arrangements with LC 15, LC 32, LC 33, LC 34 and LC 35.

I found that the licensee was able to demonstrate compliance through its procedures and written arrangements with LC 15 from the evidence provided to support closure of ONR regulatory issue 4720.

The management arrangements for LC32 were adequately made and included an appropriate Integrated Waste Strategy that reflects UK Government policy and arrangements to minimise waste accumulations on site.  I was easily able to establish  a link from the Licence Condition Compliance statement directly to local working procedures from the arrangements sampled, plant inspected and staff interviewed.  We discussed the plan to remove legacy waste from the site. The plan is challenging and has yet to commence but progress will be inspected during future visits to the site.

The management arrangements for LC33 give adequate provision for an ONR Direction for the disposal of radioactive waste.

The management arrangements for LC34 include a reliance through the current Service Level Agreement with Magnox Ltd Winfrith for borehole sampling and Inutec Ltd should consider owning this process and the associated records given it plans to conduct operations beyond that of Magnox.  I inspected instrumentation installed to detect any leakage or escape of radioactive material in a tritium laboratory and found it to be adequately installed and maintained.

I found that the licensee was able to demonstrate compliance through its procedures and written arrangements with LC 35 and has well developed register of is current total decommissioning liabilities and a supporting plan.  The register is costed and provision for a decommissioning fund is currently being developed with Inutec Ltd’s parent body organisation.

I conducted a plant walk-down to inspect the condition of the plant and the accumulations of legacy wastes.  It is my opinion that the general housekeeping with variable throughout the complex, some areas were acceptable and others need management intervention to ensure they are maintained in a suitable state.  I discussed this issue with the Inutec Ltd lead team and was assured progress would be made before my next visit.

Conclusion of Intervention

In my opinion the licensee's arrangements for compliance with LC 32, 33, 34 and 35 are adequate from the arrangements examined and the plant inspected.  In my opinion the Licensee's arrangements for compliance with LC 15 also adequate from the evidence provided.  It is my opinion that the general housekeeping needs management intervention but that there are no matters that may impact significantly on nuclear safety.