The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL), the site licensee, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for the current regulatory year (covering April 2018 – March 2019), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
This planned inspection was conducted to determine if SL Analytical Services is adequately implementing the site-wide arrangements for compliance with Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons), and Licence Condition 26 (Control and supervision of operations). SL Analytical Services facility provides a number of important roles (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of Sellafield site-wide operating facilities, including its high hazard and risk reduction work.
The overall adequacy of SL's site-wide LC12 and 26 arrangements are considered separately in other ONR inspections.
Licence Condition 12 (LC12) requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.
Licence Condition 26 (LC26) requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee.
Acknowledging Analytical Services has a need to utilise radioactive sealed sources as part of its routine activities, and a sealed source is an intrinsic hazard. My inspection, which comprised discussions with staff, examination of plant documentation, and inspection of the facility equipment, focussed on its sealed source:
Not applicable; this was not a safety system based inspection.
There were no significant findings identified during this inspection.
SL Analytical Services organisation demonstrated an adequate understanding of the site-wide LC12 and 26 arrangements. Overall, I consider that SL Analytical Services Organisation has adequately implemented its arrangements for compliance with LC12 and 26. Indeed, the implementation is good in several areas, for example its arrangements for control and release of sealed sources. However, there were also some minor areas for improvement identified, for example the disposal of redundant and embargoed sealed sources. I consider that it is proportionate to raise a Regulatory Issue here to confirm that SL Analytical Services organisation disposes of its redundant and embargoed sealed sources in a timely manner.
As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against both LC12 and LC26 as a result of this inspection.
My findings were shared with and accepted by the licensee as part of normal inspection feedback.