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, a Licence Condition (LC) 2 (Marking of the site boundary) compliance inspection was carried out on 15 September 2017.
The purpose of this inspection was for the ONR to determine the licensee's compliance with LC 2, covering both the adequacy of its formal arrangements and their implementation.
ONR carried out a one-day, on-site inspection of SL's compliance with LC 2. The inspection comprised discussions with SL staff, a targeted walk down of the site boundary, and reviews of maintenance records and other documentation.
LC 2 requires SL to make and implement adequate arrangements to prevent unauthorised persons from entering the site. It also requires the licensee to mark the boundaries of the site by fences or other appropriate means and for any such fences or other means to be properly maintained. ONR used the following guidance documentation to carry out the inspection:
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.
I found shortfalls in the licensee's written arrangements for compliance with LC 2 as regards their availability, currency, scope and ownership. At the start of the inspection, the licensee presented a document - not part of its formal arrangements - entitled 'SL Organisation Responsibility for LC2'. While this provides a useful summary of SL's approach to compliance with LC 2, it misinterprets the requirements of LC 2(2) in particular in referring to the site plan under LC 16. The licensee was unable to provide a copy of its formal, written arrangements for compliance with LC 2 prior to the start of the inspection, however these were furnished during the course of the inspection itself in the form of a compliance matrix and supporting management system documentation. One of these documents however (that pertaining to the marking of the site boundary) was inaccurate in that it refers to the old Windscale site boundary which was removed in April 2017. Also it was not apparent from the compliance matrix which part of its management system addresses LC 2(4) as regards the maintenance of the fencing and site boundary markers. Finally, the documents reviewed by ONR did not recognise ONR's primary powers under LC 2.
During my inspection, I sampled evidence associated with the licensee's compliance with its arrangements for the demarcation and maintenance of the site licence boundary. I judged that, on the basis of the evidence sampled, and the targeted site boundary walk-down, the execution of the maintenance arrangements was appropriate. I also considered that the capture, reporting, closure and trending of defects was adequate. The periodicity of the maintenance regime was suitable, however (as noted above) there was inadequate line of sight from the LC 2 compliance matrix to the maintenance instructions.
It is my opinion that the signage denoting the site boundary was suitable, however the frequency of the signage was insufficient in some areas. I communicated my observation to SL during the Inspection. SL committed to replacing signage that was misleading and, in places, insufficient in number.
From the evidence sampled during the inspection, I consider that SL has adequately implemented its arrangements for compliance with LC2. From the sample of evidence requested and examined, I can confirm that the ONR expectations as described in ONR inspection guidance 'NS-INSP-GD-02, Revision 0, issued in May 2016' were satisfied. I consider an Inspection Rating of Green (i.e. No Formal Action required) is merited against LC 2 as a result of this inspection.