The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a Licence Condition (LC) 27 (Safety Mechanisms, Devices and Circuits) arrangements inspection was carried out, as planned, on 15th and 16th January 2019. The purpose of the inspection was to determine whether SL’s arrangements are adequate to ensure the site’s compliance with LC27. The inspection comprised of discussions with SL staff and reviews of SL documentation. The inspection drew intelligence from other ONR inspections and assessments which examine the implementation of the site-wide arrangements in operating facilities.
The inspection was carried out by the Nominated Site Inspector for Sellafield, a SDFW Site Inspector, a Mechanical Specialist Inspector and a Control and Instrumentation Specialist Inspector. SL’s internal regulator, the Nuclear Independent Oversight (NIO) team, also participated.
The inspection focussed on the following areas:
ONR’s technical inspection guides NS-INSP-GD-027 Rev 4, Safety Assessment Principles – Engineering Principles: Safety Systems (ESS.1 to ESS.27) and NS-TAST-GD-003, Safety Systems formed the basis for the inspection.
Not applicable as this was not a system based inspection.
SL has developed a set of arrangements for compliance with LC27 which generally meet relevant good practice. The responsibility for delivery of LC27 sits within the Disciplined Operations section. The LC27 compliance arrangements are covered within a large number of the SL procedures and processes that cover Safety Case, Enterprise Plant Engineering/Maintenance and Disciplined Operations.
In general I was satisfied that SL has adequate arrangements in place to ensure the site’s compliance with LC27 and through discussion with SL key role holders for the implementation of these arrangements I was also satisfied that they are being applied on the SL facilities.
During the inspection it was recognised and acknowledged by SL from the Disciplined Operations assurance that there is an inconsistency in instructional compliance across the SL site in connection with LC24 (Operating Instructions) which led to SL rating their own compliance with LC27 as Yellow (Below Standard). This is an issue that ONR was already aware of prior to this inspection and has an existing regulatory issue (RI 3895) against; as such no further regulatory issue or action is required.
A number of good practices were recognised for the SL’s arrangements and the processes carried out. There was one minor area for improvement identified during the inspection and I advised SL accordingly. Notwithstanding this, overall I judge that, on the basis of evidence sampled at the time of this inspection, the licensee has adequate arrangements to ensure the site’s compliance with LC27.
The intervention was performed in line with ONR's guidance requirements (as described in our technical inspection guides) in the areas inspected.
I judge that, on the basis of evidence sampled at the time of this inspection, the licensee’s arrangements are adequate to ensure the site’s compliance with LC27. I therefore consider that the required standard was met and an inspection rating of Green (No Formal Action) is merited.
I do not consider there to be any matters that have the potential to impact significantly on nuclear safety. At present, no additional regulatory action is needed over and above the planned interventions within the Corporate Unit at the Sellafield Nuclear Site as set out in the Integrated Intervention Strategy, which will continue as planned.