Executive summary
Date(s) of inspection: November 2024
Aim of inspection
The aim of the inspection was to gain assurance that radioactive waste generated on the site is managed in accordance with regulatory requirements such that risks are reduced to ALARP through appropriate use of Best Available Techniques (BAT).
The inspection tested the adequate implementation of arrangements for minimising so far as is reasonably practicable the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated, with appropriate consideration to future demand as site approaches end of generation.
The inspection also tested the adequate implementation of arrangements for ensuring, so far as is reasonably practicable, that radioactive material and radioactive waste is at all times adequately controlled or contained to so that it cannot leak or otherwise escape, and that no such leak or escape can occur without being detected.
The inspection was a joint inspection with the Environment Agency.
Subject(s) of inspection
- LC32 - Accumulation of radioactive waste - Rating: Green
- LC34 - Leakage and escape of radioactive material and radioactive waste - Rating: Green
- LC35 - Decommissioning - Rating: Not rated
Key findings, inspector's opinions and reasons for judgement made
Licence Condition 32 - Accumulation of radioactive waste
Low level radioactive waste is segregated into separate colour-coded waste streams based on provenance which enables the effective downstream management and eventual offsite transfer for treatment or disposal. The arrangements facilitate segregation into separate waste packages based on the relevant disposal route, and include recent innovations in the available waste packages to facilitate efficiency of the system and maintain low levels of accumulations. The use of project waste management plans is well embedded and contributes to waste-led culture, with clear examples leading to minimisation of radioactive waste from projects. The inventory is divided between several systems with records for intermediate level waste held separately to low level waste. The low level waste records system, Cradle, was demonstrated to be simple and effective, but was recognised to only include waste packaged for off-site transfer. A trial is planned to implement an update which will enable tracking of waste from the point of generation which would improve the ability for station to record waste accumulated on the site, and would align more closely with wider industry practice. The arrangements provided identification of areas where waste may be accumulated, but do not specify local area limits.
Licence Condition 34 - Leakage and escape of radioactive material and radioactive waste
Tanks for storing liquid radioactive waste have appropriate level indication and are located within bunded areas equipped with sumps and moisture detection systems which alarm to local control panels. Tanks levels are routinely checked via manual plant walkdowns, with real-time level indication systems undergoing commissioning to provide enhanced monitoring. Plant defects are identified and prioritised according to significance of leak consequence, but this can lead to timeframes of several years before adequate repairs are conducted for the lowest category events. Station accepted that instances of items being stored in tank bunds was not good practice and agreed to consider reasonably practicable improvements to the storage of those items.
Licence Condition 35 - Decommissioning
Preparations for end of generation are progressing, with optioneering underway to support development of waste management plans and the site specific decommissioning plan. The waste team is already engaged with Nuclear Restoration services to inform optioneering and team capability and capacity demands reflective of the changing demand on waste teams during decommissioning.
Conclusion
On the basis of the evidence sampled, I consider that a rating of Green (no formal action) is merited for both LC32 and LC34 in respect of management of radioactive waste accumulated on the Hartlepool site.
The aspects considered under LC35 provided a cogent summary of the site's preparations for the end of generation, and whilst the overarching principles that will be followed align to the fleet wide strategy and regulatory expectations, the site-specific approach was not discussed in detail. I therefore considered it would not be appropriate to rate this aspect of the inspection.