Date(s) of inspection:
- January 2023
Aim of inspection
This inspection is a routine compliance inspection of radioactive waste related Licence Conditions (LC) 32 (Accumulation of radioactive waste) and 34 (Leakage and escape of radioactive material and radioactive waste).
The previous two LC32 inspections were both rated Amber (June 2015 and March 2018 ). The previous LC 34 inspection was also rated Amber (March 2018 ). The March 2018 inspections led to ONR raising regulatory issue 6264 which was successfully closed in September 2021. This inspection targeted assurance that the revised radioactive waste management arrangements are now fully embedded and continue to deliver adequate compliance.
RRSL’s Integrated Waste Management Strategy (IWS) is a key component of demonstrating compliance with regulatory expectations for radioactive waste management, supported by the IWS annual waste improvement plan. The inspection sampled progress against the annual plan in areas relevant to LC32 and LC34
Subject(s) of inspection
- LC32 – Accumulation of radioactive waste
- LC34 – Leakage and escape of radioactive material and radioactive waste
Key findings, inspector’s opinions and reasons for judgement made
I undertook a waste themed inspection at the Nuclear Fuel Production Plant (NFPP) operated by Rolls Royce Submarines Limited (RRSL), targeting compliance against Licence Conditions (LC) 32 (Accumulation of radioactive waste) and 34 (Leakage and escape of radioactive material and radioactive waste).
The previous LC32 and LC34 inspections, in March 2018, rated both at Amber and resulted in Regulatory Issue (RI) 6264 being raised. In response, RRSL implemented revised radioactive waste management arrangements in autumn 2020 enabling RI 6264 to be closed in September 2021. At that time ONR committed to undertaking a compliance inspection to test the maturity of the revised arrangements after a period of embedding; this is that inspection. I also sampled the Integrated Waste Strategy (IWS) annual improvement plan, through which RRSL implements measures as it seeks to continually improve its waste management practices. RRSL noted that it is now seeking build on the industry good practice it established to enable closure of RI 6264, to implement industry leading practice where practicable to do so.
RRSL has successfully reduced the total amount of radioactive waste accumulated on the site, through improved practices for waste characterisation and waste packaging, and also the opening of additional waste routes enabling historically challenging waste streams to be routinely managed and disposed of. Implementation of waste laydown areas on plant has imposed better controls on waste accumulations in operational areas which in turn is driving regular routine processing of waste for disposal. Organisational changes have improved communication between operational and environment teams, leading to an improved culture regarding radioactive waste, and consequently improved outcomes for its management on the site.
The age and design of the plant areas sampled provide some challenges for ensuring radioactive material and radioactive waste are controlled and contained such that they cannot leak without being detected. However, relevant staff were able to adequately explain the process controls utilised to manage liquors on plant, and what steps would be taken in the event of a suspected leak. Understandably, plant examination, inspection, maintenance and testing arrangements form an integral element of ensuring such control, but this inspection did not sample these arrangements. An associated LC6 / LC25 inspection (IIS-50495) did however sample relevant records.
The IWS annual improvement plan contained a good range of activities, including targeting the opening of new waste routes for problematic waste streams, acquisition of additional assay equipment, and strengthening training and resilience for relevant roles. I consider the IWS annual improvement plan to be an effective tool for providing governance for realising opportunities for improving radioactive waste management, and thus contributes effectively to delivering sustained compliance.
Based on the areas sampled, I am of the opinion that RRSL is managing the radioactive waste generated on the site in accordance with regulatory expectations, such that the total quantity of radioactive waste accumulated, and the rate at which it is produced, is minimised so far as is reasonably practicable. I am also of the opinion that, so far as is reasonably practicable, radioactive material and radioactive waste is at all times adequately controlled or contained such that it cannot leak or otherwise escape, and that suitable arrangements are in place to detect any such leaks should they occur, and respond accordingly.
I have rated this inspection of LC32 and LC34 as GREEN – no further regulatory action required, in line with ONR guidance.