Office for Nuclear Regulation

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Sellafield - Licence Condition 22 licence compliance arrangements inspection

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 & Waste (SDFW) Division.  In accordance with this strategy, a Licence Condition (LC) 22 (Modification or experiment on existing plant) arrangements inspection was carried out, as planned, on 24th and 25th April 2019.  The main purpose of the inspection was to determine whether SL’s arrangements are adequate to ensure the site’s compliance with LC22.  The inspection comprised of discussions with SL staff and reviews of SL documentation. The inspection took into account insights from other earlier ONR inspections and assessments, which examined the implementation of the site‑wide arrangements in operating facilities.

Interventions Carried Out by ONR

The inspection was carried out by: a SDFW Inspector; the SDFW Routine Permissioning Inspector;  and, a SDFW Inspector providing support to Long Term Periodic Review.  A member of SL’s internal regulator (corporate) also participated in this inspection.

The inspection focussed on the following areas:

ONR’s technical inspection guide NS-INSP-GD-022 Revision 4 “LC22:  Modification or Experiment on Existing Plant” formed the basis for the inspection.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable as this was not a system based inspection.

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

On the basis of the evidence sampled before and during this inspection I identified several Good Practices.  These related to:  the LC22 lead team’s knowledge and self‑awareness about opportunities for improvements;  effective assurance activities by SL’s internal regulator (corporate);  and, use of Plant Modification Proposal surgeries to expedite progress with modifications.

On the basis of the evidence sampled before and during this inspection I identified several relatively minor deficiencies.  These related to:  providing guidance on when SL should invoke its arrangements for construction or installation of new plant rather than its LC22 arrangements for modification on existing plant;  updating and improving the means by which SL demonstrates that its arrangements meet the requirements and good practice criteria associated with LC22;  and, updating its LC22 arrangements to deal with partially implemented plant modifications.  I have raised three Level 4 (the lowest safety significance) Regulatory Issues to monitor SL’s response to these deficiencies.

Prior to this inspection, SL’s internal regulator (corporate) had identified a more significant deficiency in SL’s arrangements for compliance with LC22.  This deficiency related to the scope of modifications under control via SL’s LC22 arrangements.  At the time of this inspection SL had started to make improvements to its LC22 arrangements to address this deficiency, but more work remains.  Since SL had identified this deficiency and had begun to address it at the time of this inspection, I have considered it proportionate to raise an additional Level 4 Regulatory Issue, rather than a Level 3 Regulatory Issue, to monitor SL’s ongoing work to address this deficiency.  This Level 4 Regulatory Issue includes relevant ONR findings arising from this inspection.

On the basis of the evidence sampled before and during this inspection I identified three matters which applied generically to all Licence Conditions, rather than only to LC22.  These related to:  the format of SL’s compliance matrix (which maps SL’s management system documents to the Licence Conditions);  arrangements for compliance with Licence Condition 1(Interpretation);  and, deployment of SL corporate processes to the operating facilities and in-the-line assurance activities at the operating facilities.  I will follow these matters up corporately with SL.  For LC22 specifically, these generic matters have been taken into account in the four Level 4 Regulatory Issues arising from this inspection.

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

Taking into account the Good Practices identified by ONR, the relatively minor deficiencies identified by ONR and the progress SL has made in addressing the more significant deficiency it had identified prior to this inspection I consider that an inspection rating of Green (No formal action) is merited, noting that the relevant guidance within ONR documentation states “Relevant good practice generally met, or minor shortfalls identified, when compared with appropriate benchmarks”.

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.