Date(s) of inspection:
- May 2023
Aim of inspection
The aim of the inspection is to test the licensee’s arrangements for minimising the accumulation of radioactive waste generated on the site, and for recording the waste so accumulated.
The previous inspection, in April 2021 (ONR-OFD-IR-21-003), was rated Amber and led to Regulatory Issue (RI) 8747 being raised. In January 2023, RI-8747 Action 1 was closed and superseded by two new Actions:
- Action 2 requires DRDL to make and implement adequate radioactive waste management arrangements, addressing the shortfalls identified in RI-6043 and RI-8128 (both of which are now superseded by RI-8747 Action 2), due for completion by 30 September 2023.
- Action 3 requires DRDL to develop a resourced strategy and plan for delivering fit-for-purpose infrastructure to deliver the radioactive waste management capability and capacity demand, due for completion by 30 April 2023.
In addition to the primary aim of inspecting compliance against LC32, this inspection will sample evidence of progress against RI-8747, with the aim of enabling closure of Action 3 and assuring confidence that Action 2 will be delivered by the agreed due date.
Subject(s) of inspection
- LC32 – Accumulation of radioactive waste – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
This inspection examined compliance against Licence Condition 32 (Accumulation of radioactive waste) as a measure of progress in DRDL’s radioactive waste management (RWM) improvement programme under RI 8747.
DRDL demonstrated improved arrangements, including the development of project radioactive waste management plans and the implementation of enhanced governance for solid radioactive waste transfers to the Nuclear Utilities Building (NUB) for processing. The business management system improvement project to update the arrangements and address RI 8747 Action 2 remains on track, but the discussions identified opportunities where DRDL’s wider arrangements (beyond those specific to RWM) could be developed to further embed a waste-led culture and contribute to LC32 compliance.
DRDL demonstrated an improving situation with respect to waste accumulations in the NUB, with further consignments planned during 2023 to reduce further the NUB inventory. However, there remain multiple examples of redundant equipment in storage with no foreseeable use but which are yet to be declared as radioactive waste by the asset owner, leading to potential undeclared waste accumulations.
The observed improvements in LC32 compliance have been enabled by the implementation of the annual integrated master schedule and associated improvements to tasking resources appropriately. However, resource constraints remain a risk to sustaining compliance. A proposed management of change to implement an expanded and reorganised RWM function is critical to achieving the wider objectives of the RWM improvement programme and securing sustained compliance with LC32.
DRDL advised that the paper it has developed in response to Regulatory Issue 8747 Action 3 was deferred from the April 2023 Nuclear Safety Committee meeting to the June 2023 iteration. Consequently RI 8747 Action 3 remains open pending separate Level 4 discussion and the due date extended to 31 July 2023.
DRDL remains on a journey to deliver the required capability and capacity to support the mission. However, I judge that evidence gathered during the inspection provided good examples of alignment to RGP and reduced total accumulations, in accordance with the expectations for LC 32 compliance. In my opinion, opportunities exist to further develop its arrangements to support embedding of a waste-led culture, but the efforts of staff within the RWM function are delivering desired outcomes. Whilst I judge there to have been good progress since the last LC 32 inspection, DRDL needs to retain focus and effort on minimising legacy holdings ahead of the new boat programmes commencing and associated radioactive waste arisings, in tandem with progressing infrastructure improvements to develop resilience. Implementing the proposed organisational changes to enhance the RWM function is critical to achieving those objectives and securing sustained compliance against LC32.
I consider in respect of LC32 noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here.
ONR will continue to monitor the wider developments for RWM via RI 8747 and associated routine engagements, with potential for further inspections at an appropriate point in the future to gauge performance when DRDL is again generating more significant quantities of radioactive waste.