The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield Site Licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The strategy requires inspections to be performed against Licence Condition 15 relating to Periodic Safety Reviews (PSR). LC15 requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases.
The purpose of this intervention was for ONR to sample and inspect the PSR for the Special Nuclear Materials (SNM) Legacy Storage facility (Stores 1 – 3) and to gain confidence that SL is taking the necessary steps to continue to operate and maintain the facilities in a manner that ensures that the plant risks are as low as reasonably practicable (ALARP).
The three broad objectives of this intervention were to:
The inspection also provided an opportunity for ONR to gather information on the storage facility and the contribution that the plant could make to ONR’s strategic priority at Sellafield (high hazard risk reduction).
ONR carried out a one and a half day LC 15 compliance inspection of the SNM Legacy Storage facility (Stores 1 – 3) over 27-28 February 2020. The ONR inspection team consisted of a Leadership and Management for Safety inspector, Civil Engineering inspector, Chemistry inspector and a PSR Project inspector. Each ONR inspector reviewed the PSR and developed topics to inspect with SL:
The intervention comprised of:
LC 15 requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases. The following ONR guidance was used:
This was not a system based inspection; therefore no judgement has been made on the adequacy of the implementation of any specific part of the safety case.
From the evidence sampled, ONR judges that SL has complied with requirements of LC 15 in carrying out a review and reassessment of safety of the SNM Legacy Storage facility (Stores 1 – 3). ONR identified three minor compliance shortfalls in relation to the PSR recommendations, ageing management and justification for re-purposing of stores which will be followed up as three Level 4 (i.e. lowest level) Regulatory Issues (RIs).
Notwithstanding the minor compliance shortfalls identified above the inspection did not reveal any matters of substantive concern that had not already been identified by SL as part of its own review or were already being progressed as part of its routine business. Closure of the shortfalls identified will be monitored by the ONR PSR inspector as part of normal, post inspection duties.
As part of its LC 15 arrangements SL will produce a Confirmation of Safety Letter to confirm that the facility has adequately implemented the PSR and that risks have been reduced to ALARP.
Based on the evidence sampled during the inspection, ONR is of the opinion that SL has implemented adequate arrangements for compliance with LC 15.
ONR judges that an inspection rating of Green (no formal action) is appropriate for compliance against LC 15 (periodic review). ONR identified three minor shortfalls which will be followed up as three Level 4 RIs.