The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL), the site licensee, against a strategy defined by the ONR Sellafield Programme. The planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This planned intervention was undertaken to determine if the Infrastructure organisation is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 22 (Modification or experiment on existing plant). The interaction targeted the implementation of Sellafield’s arrangements within Package Management and Railways (PM&R). PM&R encompasses the movement of spent fuel flasks within the Sellafield site, as well as the maintenance of these flasks to support their use to transport spent fuel from nuclear power stations within the UK to the Sellafield licensed site for reprocessing. This inspection is complementary to inspection activity undertaken by ONR transport inspectors who focus on compliance with the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009.
Licence Condition 22 (LC 22) requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.
My inspection, which comprised discussions with SL staff and examination of plant documentation, and inspection of relevant facilities, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I consider the facility’s implementation of the site’s arrangements for LC 22 is good in many areas. For instance there was good evidence of effective implementation of change management within PM&R through SL’s arrangements, both through good documentation and effective process visibility within the facilities I chose to visit. In addition, SL has recently undertaken some good work within the facilities which I visited regarding situational awareness (e.g. Plant Operations Control Centre). These are, however, offset by the shortcomings identified; specifically relating to a number of uncontrolled TPIs which SL should provide visibility and actively manage to closure. For these reasons, I consider an IIS rating of 3 (Adequate) is merited against LC 22 as a result of this inspection.
My findings were shared with, and accepted by, the dutyholders as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.