Office for Nuclear Regulation

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Sellafield - Licence Condition 9 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) 9 (Instructions to persons on the site) arrangements inspection was carried out, as planned, on 16 and 17 May 2019.  The main purpose of the inspection was to determine whether SL’s arrangements are compliant with the requirements of LC9.  The inspection comprised 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 and the SDFW Thermal Oxide Reprocessing Plant and Oxide Fuel Storage Group Site Inspector.  A member of SL’s internal regulator also participated in this inspection.

The inspection focussed on the following areas:

ONR’s technical inspection guide NS-INSP-GD-009 Revision 4 “LC9 Instructions to Persons on Site” 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:  management of access control to the site;  the alignment of the site induction to the Operator Emergency Plan;  and, the ease of retrieval of records related to LC9.

On the basis of the evidence sampled before and during this inspection I identified several relatively minor deficiencies.  These related to:  updating and improving the means by which SL demonstrates that its arrangements meet the requirements and good practice criteria associated with LC9 and updating (removing and adding) the list of SL management system documents that SL considers to be part of its LC9 arrangements;  and, defining minimum training and experience requirements for escorts to “buildings other than low hazard” in a document that forms part of SL’s LC9 arrangements.  I have raised two Level 4 (the lowest safety significance) Regulatory Issues to monitor SL’s response to these deficiencies.

On the basis of the evidence sampled before and during this inspection I identified two matters which applied generically to all Licence Conditions, rather than only to LC9.  These related to:  the format of SL’s compliance matrix (which maps SL’s management system documents to the Licence Conditions);  and, establishing a specific role for Licence Condition Owners supported by a suitable training package and competency assessment.  The first generic matter was identified in a previous inspection and is being dealt with corporately with SL.  I will also follow up the second matter corporately with SL.

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 and relatively minor deficiencies identified by ONR 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”.