Office for Nuclear Regulation

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LC22 Benchmark Inspection, Risley

Executive summary

Purpose of intervention

This was a planned ‘benchmark’ inspection, supporting ONR’s 5-year rolling programme across the licence conditions to ensure Sellafield Ltd (SL) is managing the Sellafield site safely.  It was performed to determine:

Interventions Carried Out by ONR

Licence Condition 22 requires the licensee to make and implement adequate arrangements to control modifications to its plants or processes that may affect safety.  The licence condition also imposes other duties, e.g. on experiments, on the classification of modifications and on hold-points.

This inspection was performed in two parts:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable, this was not a Safety System inspection.

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

The inspection found one significant finding: Further guidance should be included in SL’s arrangements to ensure that Plant Modification Proposals (PMP) are used appropriately whenever nuclear safety is affected, not just when intrusive physical plant modifications are required.  The inspection also led to three observations relating to: SL’s arrangements in relation to ONR’s primary powers, submission of documentation to ONR and control of urgent modifications.

The finding and the observations were discussed and a way forward agreed with SL’s Acting Process Owner for LC22 arrangements.

I am content that the Acting Process Owner’s understanding of LC22 compliance is in line with ONR’s expectations and pleased that SL is being proactive in progressing improvements to its PMP process. 

In particular, improvements have been made to the arrangements to control the number of open PMPs across the site:  The Heads of Operations are to set targets for, and review on an annual basis, the number of open PMPs in their facilities.  I am content that this will have a positive effect in reducing the number of open PMPs across the site.

Conclusion of Intervention

I have rated SL’s current arrangements as 4, Below Standard, as a result of the significant finding that the arrangements do not currently provide sufficient guidance as to when a PMP is required.

Five actions have been agreed with, and assigned to the Acting Process Owner.  Completion of these actions should see the arrangements improving to an adequate level in the related areas.

An issue has been raised in the ONR Issues database to track the completion of these actions.