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 Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on the Magnox Operating Unit (OU), as planned, in June 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 23 (operating rules), LC 24 (operating instructions), and LC 26 (control and supervision of operations). The Magnox Reprocessing Facility (MRF) was selected as the target for this inspection, as, due to a number of observed shortfalls in these LC during 2015/2016, it has been the subject of enhanced regulatory attention for the last 12 months under the oversight of the ONR Project sub-Division (part of the Sellafield, Decommissioning, Fuel and Waste (SDFW) Division).
On 28 and 29 June 2017, I carried out a two-day, on-site licence condition compliance inspection of the MRF. The inspection comprised discussions with SL staff, a targeted plant walk down, observation of and interviews with operational staff, and reviews of plant records and other documentation.
All three licence conditions require SL to make and implement adequate arrangements for the identification and use of operating rules (LC 23), the undertaking of all safety-related operations in accordance with written instructions (LC 24), and the undertaking of all safety-related operations with sufficient supervision (LC 26). As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
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.
During my inspection, I sampled evidence associated with the licensee’s compliance with its formal arrangements for the identification and implementation of operating rules within the Magnox Reprocessing Facility, and examined a sample of SL’s rules to confirm if the licensee had adequately adhered to their content. I judged that, on the evidence sampled, the licensee had implemented adequately their processes for the management of operating rules.
Additionally, I examined the management of operating instructions, concentrating on those areas where recent events indicated that the licensee may have systemic deficiencies in adherence. However, I judged that, on the evidence sampled, the licensee has adequately implemented its processes to manage the content and use of written procedures on plant, although I did note a number of minor shortfalls which merit further regulatory oversight.
Finally, I examined the quality of control and supervision on plant, with particular focus on the way in which the senior on-shift staff attain and utilise effective operational oversight to ensure sufficient control and supervision is achieved. I judged that, on the evidence sampled, the licensee had implemented adequately their processes for oversight of hazardous operations, including the provision of effective guidance to allow senior staff opportunity to apportion time on shift more effectively.
I judged that, on the basis of the evidence sampled, the period of enhanced regulatory oversight has provided sufficient targeted challenge to the licensee to improve their operational oversight on plant, whilst supporting their efforts to remove inconsistent and unduly burdensome compliance. I have communicated my findings to the Division, to support their decision regarding the requirement for any further enhanced oversight.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that, against compliance with Licence Conditions 23 and 26, an inspection rating of Green (No Formal Action) is merited.
I consider that, for Licence Condition 24, the licensee has complied with all legal duties, but that there are a number of shortfalls which they should address. I have raised an ONR Regulatory Issue to seek sufficient improvement in this area. However, these shortfalls do not represent a significant reduction in safety, and it is my opinion that an inspection rating of Green (No Formal Action) is still merited.
From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance which would prompt an inspection of those arrangements earlier than currently planned.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Conditions 23, 24 and 26 are being implemented adequately.