Office for Nuclear Regulation

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Compliance inspection of Licence Conditions 32 and 27

Executive summary

Purpose of Intervention

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. 

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 32 (accumulation of radioactive waste) and LC 27 (safety mechanisms, devices and circuits). As planned, the intervention was focussed on operational husbandry aspects of LC 32 and 27, in particular waste management, housekeeping and operation and labelling of safety mechanisms, devices and circuits, which has resulted in a regulatory issue being raised on this topic.  After a positive initial response from SL in 2017, the inspection intent was to establish if standards continue to be met in 2018 to allow the issue to be closed.

Interventions Carried Out by ONR

LC 32 requires the licensee to make and implement adequate arrangements for minimising, so far as is reasonably practicable, the rate of production and total quantity of radioactive waste accumulated on the site at any time and for recording the waste so accumulated.

LC 27 requires that the licensee shall ensure that plant is not operated, inspected, maintained or tested unless suitable and sufficient safety mechanisms, devices and circuits are properly connected and in good working order.

On 26 April 2018, I carried out a planned one-day, on-site LC 32 and 27 compliance inspection within the Magnox OU.  The inspection comprised discussions with SL staff, and reviews of plant records and other documentation.  In carrying out this inspection, the following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

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.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

I focussed on operational husbandry aspects of LC 32 and LC 27, in particular waste management, housekeeping and control and labelling of safety mechanisms, devices and circuits. There is an open regulatory issue on this topic, which guided this planned inspection.  After a positive initial response from SL in 2017, the inspection intent was to establish if standards continue to be maintained in 2018, to allow the regulatory issue to be closed.

For evidence regarding LC 32, I sampled of procedures implemented for waste management, how SL trains personnel, acts upon shortfalls identified, enables achievement of expected standards and leads a culture that minimises and manages waste effectively and safely within the Magnox Reprocessing Facility. I found that SL provides effective leadership and training to ensure a good culture in respect of waste management.

I undertook a plant visit, during which I inspected the housekeeping standards, followed up on reports of shortfalls, examined waste management areas including bins and labelling. I found the plant was held to a good standard of housekeeping and the waste was managed effectively.

For LC 27, I sampled safety mechanisms, devices and circuits from the safety case to gain evidence of implementation from the safety case. I followed the process for control and management of keys and application of lockouts required for safety mechanisms, devices and circuits on the plant. During the plant walkdown, I examined the processes in operation on plant and examined labelling, which was found to fall short of expected standards in a previous inspection.  I found that SL had raised its standards and performance since ONR’s last inspection to meet relevant good practice.

From the evidence sampled, I consider that the licensee is compliant with its legal duties under LC32 and LC27, and that there were limited opportunities for further ALARP improvements identified.  Therefore, it is my opinion that an inspection rating of Green (no formal action) is merited against both licence conditions.

As a result of the inspection, I judge that, with the identified actions adequately completed, the current regulatory issue on operational husbandry in the facility can be closed.

From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance which would prompt a further inspection of those arrangements earlier than currently planned. 

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Conditions 32 and 27 are being implemented adequately. There were no regulatory findings of significance and no follow-up regulatory action is required. The regulatory issue on operational husbandry in the facility can be closed.