Office for Nuclear Regulation

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LC23 licence compliance arrangements inspection

Executive summary

Purpose of intervention

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, Decommissioning Fuel and Waste 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 13-14 September 2016 to examine the adequacy of SL's arrangements to set the limits and conditions necessary in the interests of safety (referred to as Operating Rules), in compliance with Licence Condition 23 (LC23). 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. In addition ONR has an outstanding 'regulatory issue' (RI) concerning past failings by SL to set Operating Rules at the Sellafield site in a manner according with relevant good practice. Therefore, this intervention also looked at the extent to which SL has addressed this RI.

Interventions Carried Out by ONR

The main requirements of LC23 are, in summary, that:

ONR had established through an earlier intervention in 2015 that SL's revised standards for compliance with Licence Condition 23 meet in principle ONR's expectations as set out in our guidance. My intervention therefore aimed to examine the adequacy of the practical arrangements made to ensure that these written standards are promulgated, understood and implemented throughout the Sellafield and Windscale licensed sites.

My inspection, which comprised examination of relevant documentation and discussions with SL staff, included:

I also took into account the evidence available from ONR colleagues concerning the adequacy of recently revised SL Operating Rules in two other areas.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a Safety System inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

On the evidence available to me I consider that the licensee has made adequate arrangements for compliance with LC23.

I saw that the revised arrangements are being implemented, are found to be helpful, and are generally resulting in improvements to the setting of Operating Rules on the site. I nevertheless made some recommendations for further improvement, the most important of which were:

To consider improved rigour to the process for the setting of those nuclear safety limits and conditions which, falling below certain predicted radioactive dose thresholds, are given various terms other than 'Operating Rule' under SL's arrangements. Some of these are termed 'required operating rules' and 'operating assumptions'.

To consider reducing the onsite dose threshold for defining limits and conditions as 'Operating Rules'.

As these recommendations were accepted and as SL's current arrangements are resulting in generally acceptable and improving standards, I consider an inspection rating of 'green' (no formal action) to be appropriate within ONR guidance.

Conclusion of Intervention

My findings were shared with, and accepted by, the licensee as part of normal inspection feedback. I conclude that the current Regulatory Issue concerning LC23 arrangements can be reduced to a lower priority category.