Date(s) of inspection:
- March 2023
Aim of inspection
The aim of this inspection was to gain assurance that the Low Active Effluent Management Group (LAEMG) 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
- LC 32 – Accumulation of radioactive waste – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
I undertook an inspection of Low Active Effluent Management Group (LAEMG) 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.
Taking into account the information captured within Sellafield Ltd. internal assurance reviews and Condition Reports (CRs) related to radioactive waste management, the inspection targeted the operations within the LAEMG which led to the generation of potentially Intermediate Level Waste (ILW). This was targeted on the basis that the LAEMG is not expected to generate ILW and therefore has no management route for ILW arisings, including for those currently stored. Therefore, the inspection sought to understand:
- the origin of these arisings,
- the arrangements in place to ensure the risks associated with the accumulations of ILW on plant are reduced so far as is reasonably practicable, and
- that the arrangements are consistent with the requirements and expectations of LC 32.
The inspection sampled these arrangements within the Waste Package Encapsulation Plant (WPEP) and Effluent Plant Maintenance Facility (EPMF). During the plant walkdown of WPEP and EPMF the compliance with LC32 for the accumulations of solid Low Level Waste (LLW) was also considered.
My observations from the facility walkdown and the potential ILW inventory list provided by the Plant Solid Waste Coordinator (PSWC), is that the ILW inventory stored is low in volume, is generally not impacting upon the safety of operations, and is adequately stored to ensure that the risks to operators from its presence are reduced so far as is practicable. LAEMG is putting in place enhanced arrangements to open up management routes for any ILW inventory that may be generated, including recruitment of Suitable Qualified and Experienced Persons (SQEP) in the form of an ILW Co-ordinator. In my opinion, the recognition that appropriate management of ILW requires new SQEP resource is consistent with relevant good practice to ensure that the LAEMG nuclear baseline remains sufficient. It is my judgement that LAEMG has considered all reasonable options to seek to fulfil that role permanently. LAEMG has also sought out SQEP resource from the wider Magnox Reprocessing and Effluent Plant Operating Unit, which is targeting its time on the inventories currently stored across the LAEMG facilities. No regulatory action was taken with respect to ILW management.
During the inspection I identified a number of relevant good practices for the accumulations of LLW. However, informed by the content of the assurance reviews / CRs, minor quantities of ‘flying tipping’ had been identified across the LAEMG facilities, where the origin and ownership of waste items was lost and re-work was required in order to remove these accumulations. I, therefore, considered the adequacy of the implementation of radioactive waste relevant training generally across the LAEMG, and sampled in more detail implementation for the relevant maintenance team. I found that approximately 25% of all personnel had not completed the mandatory radioactive waste training, this increased to approximately 40% for the maintenance team sampled. On the basis that the training would enhance awareness of expectations for the management of radioactive waste; 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 waste accumulations within the facility.
Overall, based upon the sample during the inspection I was satisfied that the LAEMG is adequately implementing the Sellafield Ltd. LC32 (Accumulation of radioactive waste) arrangements. I am, therefore, content to rate LC32 as Green (no formal action). A single Level 4 (lowest level) regulatory issue has been raised from this inspection in relation to implementation of mandatory radioactive waste training (FB0097) across the LAEMG personnel.