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 Sub Division. 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 undertaken to determine if the Decommissioning Directorate is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 25 (Operational records). The intervention targeted the implementation of Sellafield’s arrangements within the FGMSP facility on the Sellafield site, and more specifically the operational records resulting from the retrieval and export of nuclear material from FGMSP to FHP. This prioritised high hazard and risk reduction programme is subject to enhanced regulatory oversight. The adequacy of facility operational records is therefore important to ensuring nuclear safety on the licensed site.
Licence Condition 25 (LC 25) requires the licensee to ensure that adequate records are made of the operation, inspection and maintenance of any plant which may affect safety. My inspection, which comprised discussions with SL staff and examination of plant documentation and the inspection of relevant facilities, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I consider the facility’s implementation of the site’s arrangements for LC 25 is good in many areas. For instance, there was good evidence in relation to operational records relating to compliance with safety case documentation and the control of the movement and accountancy of nuclear material. This is, however, offset by minor shortcomings identified; specifically in relation to the content and record retention requirement for the Quality Plan and clarity in the arrangements for aspects of record storage. For these reasons, on balance, I consider a rating of GREEN (No formal action) is merited against LC 25 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 two level 4 Regulatory Issues as a result of this inspection to follow up the minor shortfalls identified.