Office for Nuclear Regulation

To conduct a LC22 compliance inspection at the Sellafield site

Executive summary

Purpose of intervention

This intervention was undertaken on 19 May 2015 on the Fuel Handling Plant at Sellafield Limited’s nuclear licensed site at Sellafield 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).  Undertaking this intervention is consistent with this strategy, and is identified on ONR’s PP4 inspection plan which covers Sellafield Limited’s Magnox Operating Unit. This facility, operated by the licensee Sellafield Ltd (SL), was considered to be an appropriate target for an intervention because foreseeable events on this plant could result in a significant offsite release.

Interventions Carried Out by ONR

LC22 ‘Modification or experiment on existing plant’ requires the licensee to make and implement adequate arrangements to categorise and control all modifications and experiments, as defined in LC1(1), on existing plant or processes that have the potential to affect safety directly or indirectly. 

I completed the compliance inspection (comprised office based discussions) against LC22 in accordance with the following ONR guidance:

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 LC22 compliance inspection within the Fuel Handling Plant (FHP) supported by ONR’s Sellafield programme permissioning lead inspector.  The primary focus of the inspection was to confirm on a sampling basis that the licensee had implemented their extant LC22 compliance arrangements and met the expectations of LC 22.

For the a principal focus for the intervention, I identified a particular Plant Modification Proposal (PMP), which when implemented, would result in the licensee making substantive progress against the improvements necessary to close out an open Improvement Notice with a completion date of August 2015.  The secondary focus of the inspection was to understand the impact of recent revisions of the licensee’s LC22 compliance arrangements on FHP.  I specifically considered the increased use of Safety Case Implementation Plans (SCIPs) rather than PMPs to implement nuclear safety significant changes to the safety case. I also examined whether in FHP open PMPs were being closed out in an appropriately timely manner.

I was satisfied, based on my PMP sample, that the licensee was complying with the LC22 arrangements, and I found no deficiencies.  It was also my opinion that SCIPs are being used appropriately within FHP, and the requirements of the licensee’s LC22 arrangements are being met. 

It is my opinion that SL is putting considerable effort into closing down overdue PMPs in FHP and has an appropriate close out strategy in place.

It is my opinion that the licensee met the requirements of LC22 with a number of areas of good practice noted, and therefore judged an IIS rating of 3 (adequate) to be appropriate.  A higher rating of 2 (good standard) would be likely to have been appropriate if a more intelligence driven approach had been applied to closure of PMPs that were open beyond their expected closure date.

Conclusion of Intervention

No significant issues were raised as a result of this intervention.  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.