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 inspection was conducted to determine if SL’s tenant National Nuclear Laboratory (NNL) Central Laboratory is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons), and Licence Condition 26 (Control and supervision of operations). NNL Central Laboratory 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.
The overall adequacy of SL's site-wide LC 12 and 26 arrangements are considered separately in other ONR inspections.
Licence Condition 12 (LC12) requires the licensee to make and implement adequate arrangements to ensure that only suitable qualified and experienced persons perform any duties which may affect safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.
Licence Condition 26 (LC26) requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.
These duties apply to NNL even though it is a tenant on the Sellafield site.
Acknowledging NNL Central Laboratory has a need to utilise sealed sources as part of its routine activities, and a sealed source is an intrinsic hazard. My inspection, which comprised discussions with staff, examination of plant documentation, and inspection of the facility equipment, focussed on its sealed source:
Not applicable; this was not a safety system based inspection.
There were no significant findings identified during my inspection, and I have not raised any associated Regulatory Issues.
I am of the opinion that SL, as the licensee, provides an adequate level of assurance to its management and control of its tenant. In addition, NNL provides an adequate level of assurance to ownership and implementation of its safety case.
NNL demonstrates an adequate understanding of the licensee’s LC12 site-wide arrangements. Overall, I consider that NNL has adequately implemented its arrangements for compliance with LC 12 for its Central Laboratory facility. For example NNL has a transparent command and control dashboard that sets out the status of its Duly Appointed Persons (DAPs), and Suitability Qualified and Experienced Persons (SQEPs). In addition, it is taking account broader learning from outside its own organisation as part of its training improvement project. However, there were also some minor areas for improvement identified, for example the need to train persons to record Examination, Inspection, Maintenance, and Testing (EIM&T) data immediately on conducting the activity at the work face.
NNL demonstrates an adequate understanding of the licensee’s LC 26 site-wide arrangements. Overall, I consider NNL has adequately implemented its arrangements for compliance with the licensee’s LC 26 for the Central Laboratory facility. Indeed, this implementation is good in several areas, for example its arrangement in control and release of sealed sources, and demonstration of independent audits of its sealed sources being conducted. However, there were also some minor areas for improvement identified; for example its base line documentation contains ambiguity relating to its minimum safety manning level requirements.
As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against both LC 12 and LC 26 as a result of this inspection.
My findings were shared with and accepted by the licensee and NNL as part of normal inspection feedback. I have not raised any Regulatory Issues as a result of this inspection.