Office for Nuclear Regulation

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Licence Condition 7 Compliance inspection - National Nuclear Laboratory Central Laboratories

Executive summary

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 and Waste (SDFW) Division.  The planned inspection schedule for 2019/20 identifies the Licence Conditions (LCs) that will be inspected during this period.

The purpose of this planned inspection was for ONR to determine if SL’s tenant, National Nuclear Laboratory Limited (NNL), is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 7 (LC 7) – Incidents on the Site within its Central Laboratory organisation. LC7 requires NNL to make and implement adequate arrangements for the notification, recording, investigation and reporting of such incidents occurring on the NNL site

NNL Central Laboratories provide a number of important functions (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of SL site-wide operating facilities and SL’s high hazard and risk reduction activities. I sampled evidence of compliance against LC7 in the Central Laboratory facility relating to the notification, recording, investigation, and reporting of an event which occurred in October 2019. Additional sampling occurred during the inspection which included a facility inspection.

Interventions Carried Out by ONR

The site inspector and I carried out a planned compliance inspection against Licence Condition 7. This comprised discussions with SL and NNL personnel, inspection of NNL Central Laboratory areas and reviews of NNL records, documents and processes.  

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A as this was not a System Based Inspection

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

Examples of good practice were evidenced during the inspection. From sampling records and interviewing NNL personnel, I was provided with evidence that NNL have an adequate reporting culture for issues impacting nuclear safety. Furthermore, I found that such issues were appropriately sentenced, investigated, and appropriate urgent actions were taken, corrective actions raised, and closed once improvements had been made. 

Minor shortfalls identified during the inspection were in the process of being addressed or are due to be addressed over an acceptable timescale.

I found that NNL had appropriate governance to ensure that the majority of the investigations are undertaken in a timely manner and the majority of the resulting actions are completed to time. Evidence that robust, regular and frequent management review of incidents, investigation status and resulting actions occurs was provided. Further evidence indicated that NNL are making use of OPEX intelligence to drive improvement.

Conclusion of Intervention

From the evidence sampled during the inspection, I consider that NNL has effectively implemented its arrangements for compliance with LC 7 and I have assigned an inspection rating of Green (no formal action) for NNL’s compliance against LC 7 - Incidents on the site.