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. As part of this Strategy ONR carries out Licence Compliance Arrangements inspections. These examine whether SL’s site-wide arrangements are adequate to ensure the licensee’s compliance with the conditions of its nuclear site licence
This planned intervention was undertaken over 8-9 March 2016 to examine the adequacy of SL’s arrangements to control property transactions so that it remains in overall control of the site, in compliance with Licence Condition 3 (LC3). This LC was selected as part of our strategy to inspect the arrangements for compliance with all relevant licence conditions through a rolling programme over a five year period; there were no outstanding matters of concern leading to this inspection being more than normal priority.
LC3 requirements include:
“The licensee shall make and implement adequate arrangements (‘arrangements’) to control all property transactions affecting the site or any part of the site to ensure that the licensee remains in overall control of the site.”
My inspection examined SL’s arrangements, both for management of property transactions on the licensed site and for oversight of tenants for the purposes of ensuring adequate control of nuclear safety. The inspection comprised interviews with SL staff and representatives of two leaseholders, and examination of documented procedures and records.
Not applicable; this was not a Safety System inspection.
On the evidence available to me I consider SL’s arrangements for compliance with LC 3 to be broadly acceptable as practised. I did however, make a number of recommendations to ensure that good practice will be captured and applied more consistently. These included asking SL to instigate independent internal assurance of its oversight of tenants. As these recommendations were accepted and are relatively easy matters to correct, and SL’s current practice is judged to meet legal standards, I consider an inspection rating of ‘3 – Adequate’ to be appropriate.
My findings and recommendations were shared with and accepted by the licensee at a feedback session at the close of the inspection. An ONR Regulatory Issue will be raised concerning my recommendations to facilitate regulatory follow-up.