Office for Nuclear Regulation

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Compliance inspection of LC10, LC12, LC26, and LC28 at AHF

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. One such  inspection was performed to assess the Active Handling Facility (AHF) compliance with Sellafield Ltd’s (SL’s) corporate arrangements for Licence Condition (LC) 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 26 (Control and supervision of operations) and LC 28 (Examination, inspection, maintenance and testing (EIMT)).

Due to the current COVID-19 (Coronavirus) pandemic restrictions, the intervention followed a blended approach involving initially a remote interaction with the National Nuclear Laboratory Limited (NNL) personnel and SL’s Operations Control Manager (OCM) followed by a site inspection by the Remediation value stream site inspector. A remote teleconference with specialist inspectors was also available, during the site inspection, to discuss any outstanding matters. The inspection has been carried out in line with the ONR Sellafield, Decommissioning, Fuel and Waste Division’s regulatory approach to the COVID-19 pandemic.

In response to the pandemic, SL considers that their corporate compliance arrangements remain unchanged and they continue to be complied with.  Nonetheless, as a contingency SL has developed variations/ modifications 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 the arrangements for compliance with LC 10, LC 12, and LC 28.  Prior to this intervention, ONR had reviewed the relevant variations and was content that they were adequate. The intervention purpose was to determine if AHF was compliant with SL’s arrangements including with any variations that AHF had decided to utilise.

Interventions Carried Out by ONR

This compliance inspection was carried out against LCs 10, 12, 26 and 28. It sought to seek evidence of compliance in each case.

The remote element of the inspection involved discussions with representatives from AHF and the SL Nuclear Intelligence & Independent Oversight (NI&IO). This session was supported by documentation and evidence that had been requested in advance. Further evidence was requested and provided following this session. The inspection concluded with a site inspection by the Remediation value stream site inspector, and a follow-up teleconference involving the inspection team. Regulatory judgements have been made based on the verbal answers and the sampling of information contained within electronic databases and other documentation.

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

No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 10, 12, 26 and 28 arrangements at AHF.

From our inspection we concluded the following:

The three minor shortfalls will be followed up as Level 4 (i.e. lowest level) issues as part of routine regulatory business.

We provided regulatory advice to AHF in relation to the following:

Our findings were shared with, and acknowledged by, AHF’s management as part of normal inspection feedback.

Conclusion of Intervention

On the basis of the evidence sampled at the time of the inspection in relation to LCs 10, 12, 26 and 28, the inspection team judged that the NNL had adequately implemented its arrangements for compliance with Licence conditions 10, 12, 26 and 28 and has assigned an inspection rating of GREEN (no formal action required). Three Level 4 (i.e. lowest level) Regulatory Issues have been raised to manage the implementation of the identified areas for improvement.