Office for Nuclear Regulation

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Sellafield - Compliance inspection of Licence Condition 24 (operating instructions)

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield and Decommissioning, Fuel and Waste (SDFW) Programme. In accordance with that strategy, Licence Condition (LC) compliance inspections on the Plutonium Finishing and Storage Operating Unit (PF&S OU) were carried out, as planned, in May 2017. 

The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC 24 (Operating Instructions). The PF&S OU was selected as the target for this inspection, the hazard controlled by those facilities is significant and the quality of inspection and testing and the adherence to effective written inspections is a key claim made by the licensee within their safety cases for the facilities.

PF&S OU has completed extensive work updating all their Operating Instructions (OI’s) for Plutonium Management Facilities (South) (PMF(S) and Plutonium Management Facilities (North) (PMF (N) in-line with ONR issue 4619. Evidence from this inspection will inform a decision about closure of that issue.

Interventions Carried Out by ONR

LC 24 requires the licensee to make and implement adequate arrangements to ensure that all activities that may affect safety are carried out in accordance with written instructions.

On 31 May 2017, I carried out a one-day, on-site compliance inspection of the PF&S OU, targeting LC 24 performance.  The inspection comprised discussions with SL staff and reviews of plant records and other documentation. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

During my inspection, I sampled a range of written instructions from a suite that the licensee has identified as supporting safe operations within those facilities for managing plutonium products arising from reprocessing operations on site. These are also the instructions that have been updated in-line with ONR issue 4619.  In all samples reviewed, the instructions were adequate in content, were clear in presentation, and were related accurately to the relevant part(s) of the Operational Clearance Certificates.

From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with Licence Condition 24 which would prompt an inspection of those arrangements earlier than currently planned.

I judged that, on the evidence sampled the licensee has complied with all legal duties and therefore, it is my opinion that, against compliance with Licence Condition 24, an IIS rating of Green (No Formal Action) is merited.

Additionally it is my opinion that PF&S OU has demonstrated that they have addressed the shortfalls identified in ONR issue 4619. Therefore I support that regulatory issue 4619 is closed-out.

Conclusion of Intervention

My findings were shared with, and accepted by the licensee as part of normal inspection feedback. I have raised no Regulatory Issues as a result of this inspection.