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) Division. The planned inspection schedule for the current regulatory year (covering April 2018 – March 2019), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC7 (Incidents on the site). The Analytical Services Facility was selected as it provides a number of important functions (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of Sellafield site-wide operating facilities, including high hazard and risk reduction work.
On 20 November 2018, I carried out a one-day, on-site LC7 compliance inspection of the Analytical Services Facility. The inspection comprised discussions with SL staff, a targeted plant walk down, and reviews of plant records and other documentation.
LC7 requires SL to make and implement adequate arrangements for the notification, recording, investigation, and reporting of such incidents occurring on the site. As part of my preparation for the delivery of this intervention, the following ONR guidance documentation was used:
Not applicable; this was not a Safety System inspection.
Analytical Services Facility staff demonstrated an adequate understanding of the site-wide LC7 arrangements. Overall, I consider that SL Analytical Services Facility has adequately implemented its arrangements for compliance with LC7. Indeed, implementation is good in several areas, for example there is a good level of reporting, trend analysis and effective sentencing. However, I identified a specific shortfall that related to DSEAR risk assessments and some other minor areas for improvement, for example establishing an adequate audit trail for redundant chemicals. I consider that it is proportionate to raise additional actions to an extant Regulatory Issue that relates to this topic.
As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against LC7 as a result of this inspection.
My findings were shared with and accepted by the licensee as part of normal inspection feedback.