Office for Nuclear Regulation

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LC 10 & 28 Compliance Inspection – Resilience, on Sellafield Ltd.’s nuclear licensed site at Sellafield

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 (SDFW) Programme.  The 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 SL’s Resilience organisation is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 10 (training), and Licence Condition 28 (examination, inspection, maintenance and testing). SL’s Resilience organisation has ownership and is responsible for a number of important structures, systems and components that form part of the Sellafield site-wide emergency arrangements.  This intervention focus is on SL’s recently procured resilience assets as an operational and functional capability as well as its existing resilience assets.  

The overall adequacy of SL's site-wide arrangements is considered separately in other ONR inspections.

Interventions Carried Out by ONR

Licence Condition 10 (LC 10) requires the licensee to make and implement adequate arrangements for suitable training for all those on site who have responsibility for any operations which may affect safety.

My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of facilities and equipment, focussed on SL’s:

Licence Condition 28 (LC 28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety.

My inspection, which comprised discussions with SL staff, examination of plant documentation, and inspection of its facilities, focussed on SL's:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a safety system based inspection.

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

I consider the implementation of the licensee’s arrangements for LC 10 within the Resilience organisation is good in several areas. For instance, it has adopted the SL’s site-wide systematic approach to training and implemented it in accordance with the site-wide training manual. However, this is offset by not being able to demonstrate its arrangements with documentary evidence for the selected individuals during the inspection. I acknowledge this was due to a known site-wide issue that is being followed up by ONR’s Corporate Inspector.  For these reasons, and on balance, I consider an inspection rating of Green (no formal action) is merited against LC 10 as a result of this inspection.

There were no significant findings identified during my LC10 inspection, and I have not raised any associated regulatory issues.

I consider the licensee has effectively implemented some aspects of its arrangements for compliance with LC 28 within its Resilience organisation.

There were some areas of good practice, and some areas of improvements that could be made, which were accepted by the licensee.

I consider the implementation of the licensee’s arrangements for LC 28 within its Resilience organisation is good in several areas.  For instance, it has implemented an adequate asset stock control management software system. In addition, it has established an adequate arrangement to migrate its assets into an operational and functional capability. However, this is offset by the significant shortfall where I identified that its examination, inspection, maintenance and testing arrangements have not been fully established for both its new and existing assets.  I consider this matter is important enough to assign an inspection rating of Amber (seek improvement) against LC 28 and to issue two new regulatory issues here.

Conclusion of Intervention

My findings were shared with and accepted by the licensee as part of normal inspection feedback.  I have raised two new Regulatory Issues as a result of this inspection, one to track SL’s resilience assets into an operational and functional capability, and a second to track SL’s examination, inspection, maintenance and testing arrangements here back into compliance.