Licence Compliance Arrangements Inspection of Licence Condition 28 (Examination, inspection, maintenance and testing) – on Sellafield Ltd.’s nuclear licensed site at Sellafield, Cumbria.
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 Programme. The planned inspection schedule for the current regulatory year, the content of which is guided by that strategy, identifies the Licence Conditions (LC) that will be inspected over this period.
This planned inspection was undertaken to examine the adequacy of SL’s site-wide arrangements for compliance with Licence Condition 28. I concentrated on SL’s corporate-level control and oversight of these compliance arrangements to ensure the safe operation of its plant, as well as facilitating hazard and risk reduction activities on the site.
Licence Condition 28 (LC 28) requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing (EIMT) of all plant which may affect safety.
I undertook my intervention in four phases, which consisted of:
My intervention focused on obtaining evidence to enable me to judge the adequacy of SL’s corporate control and oversight of the following:
I utilised ONR guidance NS-INSP-GD-028, revision 5, EIMT, to inform my intervention.
Not applicable because this was not a safety system inspection.
In my judgement, based on the samples taken, the licensee has adequate arrangements for complying with the requirements of LC 28. I identified a number of areas of good practice, and I considered there were minor areas where the licensee could improve.
In my judgement, SL’s oversight of the implementation of non-delivery of maintenance and equipment reliability is good in many respects. Examples include training of staff assessing non-delivery, visibility of non-delivery via non-delivery reports and auditing by corporate staff. SL is also addressing the apparent shortfalls in its management of partially completed EIMT. The shortfall was identified by both SL and its internal regulator. The licensee also provided evidence of how the non-delivery of maintenance arrangements includes consideration of LC 22. These examples are offset against the opportunity to improve dissemination of operational experience / good practice across site.
I consider that the licensee has made good progress in implementing its LC 28 arrangements associated with equipment reliability. Examples of progress include issuing the equipment reliability manual and the introduction of key performance indicators for monitoring implementation of equipment reliability.
In my judgement the inspection merits an inspection rating of green (No formal action).
My findings were shared with, and accepted by the licensee. I did not raise any ONR Regulatory Issues as a result of my intervention.