The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield nuclear site licensee (Sellafield Limited (SL)) against a strategy defined by the Sellafield, Decommissioning, Fuel and Waste (SDFW) Programme. Under that strategy, ONR conducts interventions with SL to determine the adequacy of its long-term periodic review (LTPR) process, focussing on those plants on the site that are important to safety.
This intervention was part of the ONR programme of planned inspections at the Sellafield licensed site. Its purpose was to assess the adequacy of the LTPR undertaken by SL for the Alpha Residues Recovery Plant (subsequently referred to as the facility within this report). ONR undertook this inspection to ensure that SL had adequately reviewed the extant safety case and considered the capability of the facility to support future safe operations, whilst recognising that the facility is undergoing a long term decommissioning programme. In recognition of this extended programme, the inspection sought to confirm that SL was taking the necessary steps to continue to maintain and/or remediate the plant in a manner that will ensure that associated risks are maintained as low as reasonably practicable (ALARP).
Licence Condition (LC) 15 requires SL to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases. SL seeks to address this requirement by undertaking LTPRs, generally on a rolling 10 year programme. ONR reviewed the facility LTPR and undertook a two day site inspection on 22 & 23 November 2017. The LTPR project inspector was supported by a fault studies inspector and a human factors inspector. The inspection included discussions with SL staff, inspection of facility documentation and a facility walk-down. The inspection was informed by ONR's guidance on LC15 inspections and the content and conduct of periodic safety reviews.
N/A: this was not a system-based inspection (SBI).
This was an effective intervention, which benefitted from open dialogue and good cooperation between all parties. The inspection determined that SL had undertaken an adequate LTPR, which had identified four actions, none of which were considered by SL to constitute a substantive safety-case shortfall.
SL reported progress against its LTPR actions, confirming that three had been closed at the time of this inspection. SL provided an adequate reason why the fourth action remained open, along with a commitment to close it as soon as reasonably practicable, following the completion of higher priority work. SL confirmed that associated risks were being maintained ALARP in the meantime, so ONR consider this proposal to be acceptable.
The inspection did not reveal any matters of substantive concern that had not already been identified and were being addressed by the licensee following its own review, or that were already being progressed as part of routine business. The inspection did not result in any requirement to raise any regulatory issues.
ONR considers that SL has carried out an adequate LTPR of the facility and consequently, an inspection rating of Green (No Formal Action) was assigned against LC15.
As part of its LC15 arrangements SL will produce a confirmation of safety letter to confirm that the facility has adequately implemented the LTPR, and that risks have been reduced to as low as reasonably practicable (ALARP).