Office for Nuclear Regulation

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Remote compliance inspection focussed on the nuclear safety impact as a result of the covid-19 pandemic

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety.

This record describes the outcome from a planned compliance inspection at the Magnox East River (MER) facility on the Sellafield Site with specific focus on the Site Ion Exchange Effluent Plant (SIXEP) and Ponds and Inlet plant of the Fuel Handling Plant (FHP). The purpose of the inspection was to confirm Sellafield Limited’s (SL) compliance to its corporate arrangements for licence conditions (LC): 10 (Training); 12 (Duly authorised and other suitably qualified and experienced (SQEP) persons); 23 (Operating rules); 26 (Control and supervision of operations); and 28 (Examination, inspection, maintenance and testing (EIMT)).

The inspection was undertaken remotely noting the limitations currently in place as a result of the coronavirus (COVID-19) pandemic. The inspection has been carried out in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the coronavirus situation.

In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has put in place variations to its corporate arrangements which affect its arrangements for compliance with LC 10, 12 and 28. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. This inspection has included consideration of whether the variations have been used at MER, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection was carried out against LCs 10, 12, 23, 26 and 28. It sought to seek evidence of compliance in each case. However, it was recognised that given the remote nature of the intervention, a formal judgement of compliance would only be made should a sufficiently-sized sample of evidence be available under the circumstances. In this case, it was decided that a formal compliance rating was only possible against LCs 10, 12 and 28.

The inspection began with question and answer teleconference between the inspection team, representatives from MER, the Environment Agency and SL’s internal regulator, Nuclear Intelligence & Independent Oversight (NI&IO). This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session. The inspection concluded with a follow-up teleconference. Regulatory judgements have been made based on the verbal answers and supporting documentary evidence.

Explanation of Judgement if Safety System Not Judged to be Adequate

This section is not applicable.

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

Assurance was provided that MER understands the SL corporate arrangements for compliance with LCs 10 & 12 and that the arrangements are being appropriately complied with. The inspection found that MER had used the flexibility allowed by the Covid-19 variations relevant to its LC 10 and LC 12 arrangements.

The inspection gained reassurance that MER is maintaining its Control and Supervision Baseline and that the routine Operating Rule Compliance checks continue in line with the SL LC23 and LC26 arrangements.

Evidence that examination, inspection, maintenance and testing were being undertaken in an appropriate and timely manner in compliance with SL’s LC 28 arrangements was inspected. On a sample basis it was verified that, in instances where MER had decided to delay maintenance, this was deferred in line with the COVID-19 variation that SL has put in place to within its LC 28 arrangements.

Conclusion of Intervention

On the basis of the remote intervention evidence sampled at MER in relation to LCs 10, 12 and 28, I judged that the licensee had effectively implemented its arrangements for compliance with these licence conditions and has assigned an inspection rating of GREEN (no formal action required).

I judged that there was an insufficiently sized sample of evidence to underpin an inspection rating against LCs 23 and 26. However, assurance was provided regarding how MER was complying with SL arrangements and no matters were identified that would require formal follow-up.