Office for Nuclear Regulation

LC22 Compliance inspection Analytical Services Sellafield Ltd

Executive summary

Purpose of Intervention

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 undertaken to determine if SL Analytical Services is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 22 (Modification or experiment on existing plant). The Analytical Services organisation was selected as the target for this inspection as it 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 LC22 arrangements is considered separately in other ONR inspections.

Interventions Carried Out by ONR

LC22 requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which affect safety.
My inspection, which comprised discussions with staff, examination of plant documentation, and inspection of the plant equipment, focussed on SL’s arrangements to:

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a safety system based inspection.

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

The licensee demonstrated some areas of good practice, and I identified some minor areas for improvement that were accepted by the licensee.

I consider the implementation of the licensee’s arrangements for LC22 within the Analytical Services organisation is good in several areas.  For instance, the licensee demonstrated a good understanding of the recently revised site-wide arrangements and has adequately implemented them locally as part of its organisation arrangements.  Analytical Services has been proactive to adopt a site-wide initiative to reduce the number of open plant modification proposals, and has established and implemented a transparent reporting arrangement.  However, a minor area for improvement is the timely engagement of subject matter experts to ratify technical solutions. The licensee provided assurance that it would address the minor shortfalls.

 Conclusion of Intervention

As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against LC22 as a result of this inspection.

My findings were shared with and accepted by the licensee as part of normal inspection feedback.  I have not raised any Regulatory Issues as a result of this inspection.