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, Decommissioning, Fuel and Waste (SDFW) Programme. In accordance with that strategy, Licence Condition (LC) compliance inspections in the Magnox Operating Unit (OU) were carried out, as planned, in July 2016.
The purpose of these planned inspections was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with LC 26 (control and supervision of operations) and LC 27 (safety mechanisms, devices and circuits). For both inspections, I focused on the evidence of compliance within the Magnox East River (MER) facility, as the range of installed safety mechanisms and a recognised reliance on effective supervision during fuel handling operations indicated the importance of effective compliance with both Licence Conditions in this facility.
LC 26 requires that the licensee ensures that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.
LC 27 requires that the licensee ensures that a plant is not operated, inspected, maintained or tested unless suitable and sufficient safety mechanisms, devices and circuits are properly connected and in good working order.
On 13 and 15 July 2016, I carried out a planned two-day, on-site LC 26 and LC 27 compliance inspection within the Magnox OU, specifically focused on the MER facility. The inspection comprised discussions with SL staff and reviews of plant records and other documentation. 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 the management and control of safety mechanisms, devices and circuits (SMDC) within the MER facility, and reviewed the condition of a sample of installed SMDC. In my opinion, the licensee has implemented their arrangements for compliance adequately.
I also sampled the delivery of control and supervision within the same facility, focusing on the effectiveness of operational oversight by plant Duly Authorised Persons (DAP). In my opinion there were a number of instances of good practice, mainly arising from the performance of individuals as opposed to the organisational approach, which I communicated to the licensee at the time of the inspection. In my opinion, the licensee has implemented their arrangements for compliance adequately.
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 Conditions 26 and 27, an inspection 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 Conditions 26 and 27 are being implemented adequately.