Office for Nuclear Regulation

Compliance inspection of Licence Condition 22 - (modifications)

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on the Magnox Operating Unit (OU), as planned. 

The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC 22 (modification or experiment on existing plant). 

Interventions Carried Out by ONR

LC 22 requires that the licensee implements adequate arrangements to control any modification or experiment carried out on any part of the existing plant which may affect safety.  On 4 December 2018, I carried out a planned, one-day, on-site LC 22 compliance inspection within Magnox Reprocessing Facility (MRF). The inspection comprised discussions with SL staff and reviews of plant records and other documentation, plus a plant visit.  In carrying out this inspection, the following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

I examined evidence of the licensee’s compliance with its arrangements for control of modification to existing plant and consider, on the basis of my sample, that the licensee is maintaining sufficient control of the engineered systems within its facilities, and is considering all modification to those facilities in a manner proportionate to the risks posed by such changes. 

I noted that there were a small number of permanent plant modification proposals (PMP) outside the licensee’s target for closure of 3 years, though there were no temporary modifications outside the target of 1 year. I judged that the license is managing the completion of PMPs in a satisfactory manner.

I examined evidence of control of temporary plant interventions on plant, and consider that the licensee has also demonstrated that it is controlling these adequately. 

I examined the training records of those involved in the arrangements made under LC22 and found them to be adequately managed, despite a minor anomaly that the refresh period in the training database had not been updated in line with the shorter 3-yearly period now specified.

I consider that the licensee is compliant with its legal duties under LC 22, and that there are only limited opportunities for further ALARP improvements.  Therefore, it is my opinion that an inspection rating of Green (no formal action) is merited.

From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance which would prompt a further inspection of those arrangements earlier than currently planned.

Conclusion of Intervention

From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee’s formal arrangements for compliance with Licence Condition 22 are being implemented adequately. No additional follow-up regulatory action is required above the actions identified in an extant ONR Regulatory Issue regarding management of training.