Licence Condition 36 compliance inspection - National Nuclear Laboratory Central Laboratory

• Site: Sellafield
• IR number: 19-008
• Date: June 2019
• LC numbers: 36

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, Decommissioning, Fuel and Waste (SDFW) Division.  The planned inspection schedule for 2019/ 20 identifies the Licence Conditions (LCs) that will be inspected during this period.

The purpose of this planned inspection was for ONR to determine if SL’s tenant, National Nuclear Laboratory Limited (NNL), is adequately implementing the licensee’s site-wide arrangements for compliance with LC 36 (“Organisational capability”) within its Central Laboratory organisaton.  I focused on sampling evidence of compliance in the Central Laboratory facility since this provides a number of important functions (e.g. material characterisation, chemical, physical and radiometric measurement and analysis) that support the safety of Sellafield site-wide operating facilities and SL’s high hazard and risk reduction work.

The overall adequacy of SL's site-wide LC 36 arrangements is considered separately in other ONR interventions.

Interventions Carried Out by ONR

Licence Condition 36 requires that the licensee provides and maintains adequate financial and human resources to ensure the safe operation of the licensed site.  These duties apply to NNL operating the Central Laboratory facility as SL’s tenant on the Sellafield site.

I carried out a planned LC 36 compliance inspection of the Central Laboratory facility.  My inspection focused on:

• NNL’s nuclear baseline for the Central Laboratory facility (i.e. the means by which NNL demonstrates the adequacy of its organisational structure, staffing and competencies to manage nuclear safety);
• The change process followed by NNL when implementing changes to the organisational structure for the Central Laboratory;
• NNL’s compliance with SL’s arrangements for determining, and ensuring compliance with, Minimum Safety Manning Levels (MSMLs) for the Central Laboratory facility; and
• SL’s management and control of its tenant in relation to assuring compliance with the licensee’s arrangements for LC 36.

The inspection comprised discussions with SL and NNL staff, review of records, and sampling of information contained within electronic speadsheets and other documentation.

Explanation of Judgement if Safety System Not Judged to be Adequate

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

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

No significant matters were identified as requiring immediate regulatory attention.