Office for Nuclear Regulation

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To conduct LC11, LC25 and LC35 compliance inspections and undertake routine regulatory interactions with Sellafield Limited

Executive summary

Purpose of intervention

This intervention was undertaken on 8 – 11 December 2014 at Sellafield Limited’s Sellafield nuclear licensed site in Cumbria.

Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part of ONR’s activities.  ONR’s Sellafield Programme has defined a programme of system inspections and LC compliance inspections to be undertaken on the Sellafield site, this is a key aspect of ONR’s regulatory strategy (for the Sellafield site).  The inspections undertaken within this intervention are part of that programme and are identified on ONR’s PP4 inspection plan which covers Sellafield Limited’s Magnox Operating Unit.

Interventions Carried Out by ONR

LC11 ‘Emergency Arrangements’ requires the licensee to make and implement adequate arrangements for dealing with any accident or emergency arising on the site and their effects.

LC25 ‘Operational Records’ requires the licensee to make records of what has happened on the plant, checks on safety related parameters and plant configuration, what was found as a result of inspection and what work was done to repair, service of refurbish equipment.  LC25 also requires the licensee to keep records of the amount and location of any radioactive material (including fuel and waste).

LC35 ‘Decommissioning’ requires the licensee to make and implement adequate arrangements for the decommissioning of any plant or process which may affect safety, and to make arrangements for the production and implementation of decommissioning programmes for each plant.

I completed compliance inspections against these LCs in accordance with the following ONR guidance:

I also attended a number of planned meetings as part of my routine interactions, and made initial enquiries about an event that took place during my visit.

Explanation of Judgement if Safety System Not Judged to be Adequate

N/A.  This was not a safety system inspection.

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

I undertook a LC11 compliance inspection within the Fuel Handling Plant which falls within the Magnox East River (MER) group of facilities.  There is a robust Emergency Preparedness & Response (EP&R) capability within MER, and many of the known shortfalls in the corporate (Sellafield Limited) EP&R arrangements have been addressed within the MER arrangements.  I noted that a number of key EP&R performance targets within MER were set at higher levels than those required by the corporate arrangements, and were being achieved.  There is a resourced plan to further improve MER’s EP&R capability, which includes improvements identified through its ongoing programme of exercises and drills.  I witnessed an emergency drill which I judged to be an adequate demonstration of the MER EP&R capability. Based on my sampling inspection the MER EP&R arrangements and capability meet the requirements of ONR’s guidance on LC11 and I judge an IIS rating of 3 (adequate) to be appropriate against LC11. 

I undertook a LC25 compliance inspection (which sampled records of what had happened on plant) within the Magnox Reprocessing Plant.  My inspection identified that the local (to the Magnox Reprocessing Plant) procedures identifying the records to be kept, the period of retention and the persons responsible for implementation are not up to date.  The corporate procedures did not provide this detail in sufficient depth to constitute procedures against which I could judge compliance at the Magnox Reprocessing Plant.   In the absence of a procedure, the records retained, and the retention period is set based on the knowledge and experience of those responsible for record keeping (who are not identified in procedures).  I examined a sample of operational records and found them to be complete, and stored in a secure and logical fashion that would facilitate recovery should this be required at some point in the future.  The licensee had already recognised that a key local procedure was out of date (and has an existing action to address this), but had not appreciated the extent to which there was a lack of procedures for management of operational records.  I consider the licensee’s compliance with LC25 is below the expected standard, and judge an IIS rating of 4 (below standard) to be appropriate.  A lower rating was not appropriate given the licensee readily accepted that up to date procedures were required and accepted an action to develop a suitable set of procedures that will ensure that all operational records at the Magnox Reprocessing Plant are managed in line with the corporate procedures within an acceptable timescale.

I undertook a LC35 compliance inspection within the Magnox Reprocessing and Thermal Denitration (TDN) and Medium Active Evaporation plants which focussed on preparations for Post Operational Clean Out (POCO, which is the transition between plant operations and decommissioning).  The licensee confirmed preparations for POCO for both plants are due to start in 2015.  A key aim of timely POCO is to avoid creation of waste legacies that will fall to future generations to manage, and successful POCO is an opportunity to gain and retain knowledge that will facilitate future decommissioning.  The licensee is exploring knowledge management tools that will preserve the information gained through POCO, with a link into relevant data sources from the plant operations.  The licensee is reviewing the corporate decommissioning arrangements against ONR’s LC35 guidance, as a previous ONR intervention identified some gaps.  In the interim, I am satisfied that the licensee is proactively planning for POCO in the Magnox reprocessing and TDN plants, and that there is a decommissioning plan in place for both plants which is in a suitably developed state for plants with five years left to operate.  I judged an IIS rating of 3 (adequate) to be appropriate against LC35.  It would be appropriate for ONR to undertake another LC35 inspection focussing on these plants in 3 years’ time, when the plans for POCO will be further developed.

I also attended a number of meetings for information-gathering and routine updates on a number of topics.  From a regulatory perspective, the key meeting I attended was the outage intentions meeting for the Magnox Reprocessing Plant 2015 periodic shutdown, where I confirmed that ONR would reduce our regulatory involvement (relative to pervious periodic shutdowns) and take credit for the assurance activities undertaken by the Sellafield Limited Internal Regulator.  The rationale for this will be set out in a forthcoming Project Assessment Report.

Conclusion of Intervention

One Regulatory Issue was raised as a result of this intervention, arising from my findings against LC25.  I will manage its close out as part of normal regulatory interactions with the licensee. Based on the evidence gathered, no significant matters have been identified that are likely to impact on nuclear safety on the Sellafield site at this time.