Office for Nuclear Regulation

Readiness inspection for HAW Exports to Sellafield Ltd

Executive summary

Purpose of Intervention

ONR undertook a reactive inspection of the Atomic Weapons Establishment’s (AWE’s) readiness to package and transport Higher Activity Waste (HAW) drums to Sellafield Ltd. (SL) from a temporary dispatch area in an existing HAW drum store within the Solid Radwaste Services (SRS) Complex.  The purpose of the inspection was to seek evidence of the adequate implementation of AWE’s new process and supporting arrangements.  The findings of the inspection will be used to inform the decision in response to AWE’s request under Licence Condition 22(1) for ONR’s agreement to commence the HAW export operations.

The HAW will be transported using a NOVAPAK transport set, comprising two Type B transport containers; the NOVAPAK has been previously used to transport civil wastes from Harwell to SL, under license by ONR.  However, the Competent Authority for transport of AWE HAW is the Defence Nuclear Safety Regulator (DNSR), as SL will only take ownership of the waste on its entry onto the Sellafield Nuclear Licensed Site.

Interventions Carried Out by ONR

On 12, 16 and 17 March 2021, I, along with the Waste, Decommissioning and Transport Site Inspector, carried out a readiness inspection at the Aldermaston site to assess the adequate implementation of arrangements to safely commence HAW exports to SL in accordance with the safety case.

The inspection comprised, desk-top based discussions (remote and on site), review of documentation and observation of operators undertaking the activities associated with receipt, loading and dispatch of the transport container for HAW drums.  The inspection was conducted in accordance with the relevant ONR guidance document for this licence condition, NS-INSP-GD-022 Revision 6, and as part of my preparation for the delivery of this intervention, the following ONR guidance documentation was also used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection.

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

Overall, I consider that the licensee has adequately demonstrated their arrangements to safely undertake activities associated with HAW exports to SL.  However, I found the following shortfalls:

In addition, I found that AWE has not made adequate progress in transitioning the export process and arrangements to the permanent Logistics Facility; this represents a risk to hazard reduction on site in the long term as the targeted export rates cannot be achieved from the temporary dispatch area.

Conclusion of Intervention

This Intervention Record will be used as part of the evidence to recommend the release of ONR regulatory hold point in support of the agreement to grant permission to commence HAW exports to SL.

Based on the evidence sampled at the time of this intervention, I consider that the licensee has adequately demonstrated their ability to safely undertake activities associated with the packaging and transport of HAW to SL.  However, I found one shortfall in relation to documentation that I require to be addressed prior to permissioning and have raised a Level 4 Regulatory Issue to track the licensee’s progress.  In addition, I found shortfalls in AWE’s arrangements relating to training, role definition and future capability, which I have also included as requiring action in the Level 4 Regulatory Issue; however, I judge that these four shortfalls should not preclude permissioning and can be monitored to completion by ONR through routine regulatory engagements with the HAW Programme.

I consider that, on the basis of evidence sampled at the time of this inspection, the licensee has adequately implemented its arrangements for compliance with LC 22 (Modification or experiment on existing plant).  I therefore consider that an inspection rating of Green is merited.