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 & Waste Programme. As part of this strategy, ONR carries out Licence Compliance Arrangements inspections. These examine whether the SL's site-wide arrangements are adequate to ensure the licensee's compliance with the conditions of its nuclear site licence.
This planned inspection was undertaken to examine the adequacy of SL's site-wide arrangements for compliance with Licence Condition 5 (LC 5). This LC was selected as part of the strategy to inspect SL's arrangements for compliance with all relevant licence conditions through a rolling programme over a five year period. There were no particular matters of concern leading to this inspection being more than normal priority.
LC 5 requires that the licensee follows certain requirements in regard to consigning nuclear matter from the licensed nuclear site. Firstly, to ensure that the transfer of nuclear matter (other than excepted matter and radioactive waste) to sites in the UK (other than to so-called “relevant sites”) is carried out only with the consent of ONR. Secondly, that records are kept of all such nuclear matter consigned from the site. These records need to be kept for a minimum of 30 years except in the case of items that are stolen or lost, etc. where record retention for 50 years is required.
My inspection, in which I was supported by an ONR specialist radioactive transport inspector, comprised discussions with SL staff and examination of SL documentation. I focussed on the following areas:
Not applicable; this was not a safety system inspection.
I found SL's arrangements for compliance with LC 5 to be good in many areas. For instance there is a good level of governance demonstrated by SL's Office for Consigning Authority; a good level of control (through delegated authority arrangements) and records-keeping related to consignment; and a robust “handshake” process is in place. In addition, SL's staff were knowledgeable regarding the inspection's subject areas and provided many good quality responses to our questions. However, these aspects were offset by minor shortcomings in a number of aspects. In particular, I advised that SL's arrangements are too focussed on transport aspects and this complicates its demonstration of compliance with LC 5.
I was nevertheless satisfied that SL is compliant with LC 5 and I therefore awarded an Inspection Rating of Green (No Formal Action).
My findings were shared with, and accepted by the licensee as part of normal inspection feedback. I have raised a new Regulatory Issue as a result of this inspection to track SL's development of arrangements that provide a clearer demonstration of how it meets its duties under LC 5.