Date(s) of inspection:
- January 2023
Aim of inspection
The aim of this inspection was to gain assurance that Spent Fuel Services (SFS) is adequately implementing the Sellafield Ltd corporate Licence Condition (LC) 32 (Accumulation of radioactive waste) arrangements. The inspection was conducted jointly with the Environment Agency given the common expectations between LC 32(1) and the Radioactive Substances Regulation (RSR) Environmental Permitting Regulations (EPR).
Subject(s) of inspection
- LC32 – Accumulation of radioactive waste – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
I undertook an inspection of Spent Fuel Services’ (SFS) implementation of the Sellafield Site arrangements for LC32 (Accumulation of radioactive waste). The inspection was completed jointly with the Environment Agency who undertook its assessment of compliance with the relevant RSR EPR Permit conditions relating to solid waste management. The Environment Agency will issue its own report on the inspection.
Given ongoing regulatory focus and engagement on the Advanced Gas-cooled Reactor Operating Programme (AGROP), I took the decision to target the Fuel Handling Plant (FHP) which plays a pivotal role in the dismantling of AGR fuel to support the safe long-term interim storage of AGR fuel on the Sellafield site.
I found that FHP was both managing operational wastes (the inspection sampled the management of graphite, stainless steel and miscellaneous consumable items categorised as exempt waste, Low-Level Waste (LLW) and Intermediate Level Waste (ILW) associated with AGR fuel dismantling), and proactively working on reducing accumulations of legacy wastes through applying relevant good practices such as sorting / segregation prior to transfer from the facility to ensure effective use of the waste hierarchy.
Due to the number of audits / Condition Reports (CRs) raised relevant to LC32, Sellafield Ltd highlighted a number of improvements that it has put in place to support radioactive waste management activities. During the inspection and informed by the content of the audits / CRs, I sampled the training records for the relevant maintenance team and found that approximately 50% of maintenance staff had not completed their mandatory waste training; a Level 4 (lowest level) regulatory issue has been raised to address this issue.
During the plant walkdown I raised several minor observations and provided regulatory advice on opportunities to improve the management of exempt wastes and LLW accumulations within the facility.
I observed the accumulations of radioactive waste from operations / maintenance within the dismantler cells to be high. The export route has been unavailable for several months and once available, waste management activities will have to be managed alongside dismantling operations due to the use of common equipment. No documented plan was available at the time of the inspection to articulate that all reasonable arrangements were in place to minimise the rate of production and accumulation of this radioactive waste stream, although the operational staff articulated opportunities which could be implemented ahead of the export route being available.
I am satisfied that this is not an immediate safety shortfall (the waste is in a shielded area), however given:
- the quantity of radioactive waste accumulated;
- the increase in contamination during the extended storage within the dismantler cell (potentially decreasing the quantity of waste which could be diverted from the proposed Geological Disposal Facility);
- the absence of records for radioactive waste until suitable sorting / segregation into red liners (or suitable LLW container) is completed; and
- the absence of a plan to regain control over the inventory / minimise accumulations during a prolonged outage of the export route. I judged there to be a shortfall against the requirements of LC32(1) and have raised a Level 3 regulatory issue to address this shortfall.
On the basis of the shortfalls identified around the accumulation of ILW within the FHP dismantler cells, I consider that Sellafield Ltd was not meeting relevant good practice and have rated the inspection as Amber (seek improvement); a Level 3 regulatory issue (RI) has been raised and the shortfalls will be managed by way of this RI. A second Level 4 (lowest level) regulatory issue has been raised to capture improvements to address gaps within the training records for radioactive waste management.