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 2017 - March 2018), 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 a joint inspection with the Environment Agency to determine if SL’s Analytical Services organisation is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 35 (LC35, Decommissioning). The Analytical Services organisation provides a number of important roles (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of Sellafield site-wide operating facilities, including its high hazard and risk reduction work. This intervention focussed on inspecting the Analytical Services organisation’s highly and medium active cells.
The overall adequacy of SL's site-wide LC35 arrangements is considered separately in other ONR inspections.
LC35 requires the licensee to make and implement adequate arrangements for the decommissioning of any plant or process which may affect safety.
My inspection, which comprised discussions with licensee staff, examination of plant documentation, and inspection of its facilities, focussed on SL’s arrangements to:
Not applicable; this was not a safety system based inspection.
I identified no significant shortfalls during the conduct of this inspection. Nevertheless, I consider it proportionate to raise a minor Regulatory Issue to track the licensee’s progress to establish a detailed decommissioning strategy for its near term planned decommissioning projects.
The licensee demonstrated some areas of good practice, and I identified some areas for improvement that were of a minor nature and accepted by the licensee.
I consider the implementation of the licensee’s arrangements for LC 35 within the Analytical Services facility is good in several areas. For instance, it has established an overarching decommissioning strategy, plus a number of supporting detailed decommissioning strategies for specific extant decommissioning projects. However, this is offset by the maturity of its detailed strategy for its near term planned decommissioning projects which are being established. For these reasons, on balance I consider an inspection rating of Green (No formal action) is merited against LC 35 as a result of this inspection.
My findings were shared with and accepted by the licensee as part of normal inspection feedback. I have raised one new minor Regulatory Issue; to track the licensee’s establishment of a formal decommissioning strategy for its near term planned decommissioning projects.