The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Programme. In accordance with that strategy, a Licence Condition (LC) compliance inspection on the Magnox Operating Unit (OU) was carried out, as planned, in April 2016.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 7 (Incidents on the site). The Fuel Handling Plant (FHP) was selected as the target for this inspection as safe storage of used fuel is central to the continued delivery of Advanced Gas-cooled Reactor (AGR) and Magnox reprocessing operations, an important aspect of sustained high-hazard reduction on site.
On 13 April 2016, I carried out a one-day, on-site LC7 compliance inspection of the Magnox OU. The inspection comprised discussions with SL staff and reviews of plant records and other documentation.
LC7 requires SL to make and implement adequate arrangements for the notification, recording, investigation, and reporting of such incidents occurring on the site. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
During my inspection, I sampled evidence associated with the licensee's compliance with its formal arrangements for the review of events within the Fuel Handling Plant facility, and examined a sample of SL's completed formal investigations to determine whether the licensee had encouraged a robust and effective level of self-challenge in delivery of those investigations.
Additionally, I examined the content and timeliness of delivery of a sample of corrective actions that had been raised by the facility in response to those events that had occurred within the facility over the last twelve months in order to establish the extent to which the licensee was able to effectively manage the burden of actions generated as a result of the investigation of events. I judged that, on the evidence sampled, the licensee has adequately implemented its processes to ensure the adequate identification, reporting and investigation of events that that occur within the facility and had demonstrated appropriate management of the corrective actions associated with such events.
Furthermore, I recognise that the licensee, as part of a site-wide pilot study at this stage, has started to embed the revised site processes and arrangements for the management of events and their related investigation. It is my opinion that the initial evidence from this inspection shows that these revisions are effective; the licensee has already recognised the benefit of these changes and should now consider the timing and extension of the pilot programme to include the remaining parts of the site.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that, against compliance with Licence Condition 7, an IIS rating of Green (No Formal Action) is merited.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Condition 7 are being implemented adequately.