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. My planned inspection schedule for the current regulatory year (covering April 2016 - March 2017), 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 National Nuclear Laboratory's (NNL's) Central Laboratory, (termed the BTC, British Technology Centre), is adequately implementing SL's site-wide arrangements for compliance with Licence Condition 22. This facility was selected for inspection since it contains a significant inventory of nuclear and radioactive material, and the quantity of such material and associated scope of operations is likely to grow in the future, as more of the facility undergoes active commissioning. It is also proposed that analytical services for the Sellafield site may transfer from another facility to the BTC in the future. It should be noted that although the facility is on the licensed site, and hence duties under the licence conditions rest with SL, the facility is operated by NNL as a tenant.
This inspection has targeted the implementation of SL's site-wide arrangements for Licence Condition 22 by the NNL Central Laboratory. The adequacy of SL's site-wide arrangements more generally is considered in other inspections.
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 and NNL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I consider that the licensee has effectively implemented its arrangements for compliance with LC22.
I consider the facility's implementation of the site's arrangements for LC22 is good in many areas. For instance, the staff interviewed had a good knowledge of the existing arrangements, and provided good evidence to this effect in response to questions. This is, however, offset by the opportunity for improvements, such as revising the procedures for dealing with Temporary Modifications used within the facility to ensure that records clearly show where these have been closed out, and also improving management visibility and oversight of these Temporary Modifications. For these reasons, on balance, I consider the inspection merits an IIS rating of Green, (No Formal Action), against LC22.
My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I have raised no Regulatory Issues as a result of this inspection.