Office for Nuclear Regulation

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Special Nuclear Materials Operating Unit (SNM OU) compliance inspection and INF1 follow up

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, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with that strategy, two Licence Condition (LC) compliance inspections of the Special Nuclear Materials Operating Unit (SNM OU) was carried out, as planned in June 2018.

The purpose of these planned inspections was for ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC27 (Safety mechanisms, devices and circuits (SMDCs)) and LC 28 (Examination, inspection, maintenance and testing (EIMT)). For the inspection, I focused on the evidence for compliance within Special Nuclear Material - South (SNM(S)) facility.

Interventions Carried Out by ONR

On 14 June 2018, I, the site inspector for the SNM OU, accompanied by the SCIE Delivery Lead carried out a one day planned LC27 and LC28 licence condition inspection within the SNM (S) facility, targeting Finishing Line 6 (FL6). The SNM OU SL Nuclear Independent Oversight (NIO) representative participated in the inspection also.

The inspection comprised discussions with SL personnel, and reviews of SL records, documents and processes, followed by a plant walk down.

In addition I also conducted follow up enquires into two recent events which occurred in SNM (N) reported under INF1s 2018/99 and 2018/326.   

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

During my inspection, I sampled evidence associated with SNM (S) compliance with LC27 and LC28.

For LC 27, I sampled documents for safety mechanisms, devices and circuits (SMDC’s) from the engineering schedule to gain evidence of implementation as required from the safety case. I reviewed the fault sequences for selected SMDC’s and associated clearance certificates. During the plant walk down I examined the SMDC’s in operation on plant and found for the operational ventilation system they were labelled and working correctly.

For LC 28, I sampled the maintenance requirements and completed maintenance records for the SMDC’s I selected as part of my inspection. I reviewed the suitability of persons identified to carry out and supervise EIMT activities by sampling the training records of the persons who carried out work on the selected SMDC’s. 

After reviewing the evidence for LC27 and LC28 I identified no shortfalls, other than one observation in respect of LC27 and SL’s completion of a related clearance certificate. This will be followed up by SL’s NIO and I will follow up through routine engagement, as necessary. There were no significant findings identified during this inspection.

Follow up on action plan for BN 1802A0658 – INF1 2018/99

The purpose of the engagement was for SL to present their plan of how they will address the actions identify from ONR’s follow up enquiries into this event. I am satisfied that SL is taking the appropriate steps to address those actions.

Follow-up enquiries on BN 1805A1384 – INF1 2018/326

The purpose of the engagement was to establish further details of the event following initial notification to ONR, consider SL’s response so far and judge whether further investigation is warranted.  I have reviewed this event against the ONR investigation criteria described in ONR-ENF-GD-005 Revision 2, and I am satisfied that the event does not meet ONR’s investigation criteria and do not consider that a formal investigation is required.

The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.

Conclusion of Intervention

 From the evidence gathered during this intervention, I consider that the licensee is compliant with its legal duties under LC27 and LC28 and therefore, it is my opinion that an inspection rating of Green (no formal action) is merited.

My findings were shared with and accepted by the licensee as part of normal inspection feedback.