This intervention was undertaken on 1 and 2 September at the Magnox Reprocessing Plants on Sellafield Limited’s Sellafield nuclear licensed site in Cumbria. Inspection of Licence Condition (LC) compliance at nuclear licensed sites forms a significant part of Office for Nuclear Regulation’s (ONR) 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.
ONR requires the licensee (Sellafield Limited [SL]) to shut down the Magnox Reprocessing Separation Plant under LC30, periodic shutdown, for the purposes of enabling any examination, inspection, maintenance and testing (EIM&T) to take place. The EIM&T activities are undertaken in accordance with LC28, EIM&T. Under LC30 (3) SL requires a Consent from ONR to resume operating the Magnox Reprocessing Separation plant on completion of the periodic shutdown.
This intervention was a key element of ONR’s permissioning work associated with the Magnox Reprocessing Separation Plant 2015 periodic shutdown, and comprised a LC28 compliance inspection.
LC28 requires the licensee to make and implement adequate arrangements for the regular and systematic EIM&T of all plant which may affect safety.
My inspection, which comprised discussions with SL staff, examination of selected samples of plant documentation, and physical inspection of selected samples of EIM&T activities, focused on the following areas:
Not applicable; this was not a safety system inspection.
At the time of my inspection the 2015 periodic shutdown was behind schedule. As a result of the delays not all the plant inspections undertaken by SL to demonstrate compliance with LC28 that I had planned to sample had been completed. SL has not removed any planned inspections from its LC30 programme, and to date has one emergent issue which it is addressing via its due process.
I consider that for the areas sampled SL has demonstrated compliance with the requirements of LC28. It was my opinion that there were a number of areas of good practice and a few minor areas for improvement. Areas of good practice included improvements to the inspection scope documents (including ONR recommendations from the 2012 periodic shutdown), control and supervision of contractor inspection activities, and improvements to the inspection reports. The minor points include one example of inconsistent control of inspection documentation, and the lack of initial evidence for the link between safety significant documentation. Overall, I consider an IIS rating of 2 (good standard) against LC28 is justified.
I will use the findings of this inspection to inform my assessment of SL’s LC28 activities undertaken during the periodic shutdown. My assessment report will form part of ONR’s assessment of SL’s request for Consent to start up the Magnox Reprocessing Separation Plant on completion of the 2015 periodic shutdown.
The intervention was performed in line with ONR’s guidance requirements (as described in our technical inspection guides) in the areas inspected.
The findings of my inspection have been shared with the SL, who accepted them. I did not raise any ONR regulatory issues as a result of this inspection.