Office for Nuclear Regulation

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Planned Licence Condition 22 compliance inspection at the First Generation Magnox Storage Pond

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with Sellafield Limited (SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, planned Licence Condition (LC) compliance inspections are undertaken. LC 22 requires that the licensee implements adequate arrangements to control any modification or experiment that may affect safety for extant plants and / or processes.  This inspection was undertaken to determine the adequacy of SL’s implementation of arrangements to safeguard compliance with LC 22, within the First Generation Magnox Storage Pond (FGMSP) area of remediation. 

Interventions Carried Out by ONR

On 4th June 2019, I carried out a planned LC 22 compliance inspection within FGMSP. The inspection comprised discussions with SL staff, reviews of plant records / related documentation, and a plant visit.  In carrying out this inspection, I took cognisance of ONR guidance presented in NS-INSP-GD-022, Revision 4 (January 2018).

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable, this was not a system based inspection.

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

I sampled evidence of SL’s compliance with its arrangements for control of modifications within FGMSP and consider that SL:

I confirmed that at the time of inspection, nine permanent plant modification proposals (PMP) are outside SL’s target, for closure within 3 years. I confirmed that there were no temporary modifications outside SL’s closure target of 1 year. On the basis of this inspection I judge that SL is adequately managing PMPs. I also examined evidence of SL’s management of Temporary Plant Interventions (TPI), and consider that SL is adequately controlling these, with an improvement plan in place to further improve their management of TPIs.  I sampled the training records of SL personnel involved in the implementation of its LC22 arrangements and found that associated training is being managed appropriately.

From those areas sampled, I did not identify any significant shortfalls in SL’s application of its formal arrangements for compliance with LC22. Overall, I consider that SL is compliant with its legal duties under LC 22, and that there are only limited opportunities for further ALARP improvements.  Therefore, it is my opinion that an inspection rating of Green (no formal action) is appropriate.

Conclusion of Intervention

Based upon my LC22 inspection within FGMSP, I judge that SL has adequately implemented its formal arrangements for compliance with Licence Condition 22. No requirement was identified for any follow-up regulatory action. However I confirmed that SL’s Nuclear Independent Oversight (NIO) representative (who was present during the inspection) will continue to monitor progress of the improvements identified within FGMSP.