In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety. One such inspection was performed to assess the Special Nuclear Materials (SNM) Value Stream’s compliance with Sellafield Ltd’s (SL’s) corporate arrangements for LC 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), and LC 28 (Examination, inspection, maintenance and testing (EIMT)). The SNM Value stream is sub-divided into SNM (North and South).This intervention considered the SNM (North) activities.
This intervention was undertaken remotely from site due to the restrictions in place during the current COVID-19 (Coronavirus) pandemic.
In response to the COVID-19 situation, SL has recognised that its corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency SL has developed variations/ modifications to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has put in place variations to its corporate arrangements which affect its arrangements for compliance with LC 10, LC 12 and LC 28. Prior to this intervention, ONR had reviewed the relevant variations and satisfied itself that they are adequate. The intervention purpose was to determine if SNM was compliant with SL arrangements including with any variations SNM had decided to utilise.
With ONR specialist support, I carried out this compliance inspection against LCs 10 (Training), 12 (Duly authorised and other suitably qualified and experienced persons), and 28 (Examination, inspection, maintenance and testing). Compliance with a number of other LCs was sampled but was noted rated as part of this inspection.
The intervention commenced with a question and answer telecom at which I requested supporting evidence. I then undertook a desktop review of the evidence, and held a subsequent clarification telecom. I then made judgements based on the adequacy of the assurances provided and supporting documentary evidence.
N/A as this was not a System Based Inspection.
I received assurance that SL understands what the nuclear safety requirements are in terms of safety demands on people and plant for the current status of the plant and that they have been adequately meeting those demands. Furthermore, I received assurance that those facilities that had been shut-down to mitigate the demands on people and plant during the COVID-19 situation, had been shut-down in a controlled manner as would be the case for when preparing them for a routine long-term outage.
I inspected the underpinning evidence for some aspects of the assurances received during the intervention. This included evidence that SNM had not needed to use the flexibility allowed by the variations relevant to its LC 10 and LC 12 arrangements. Evidence was inspected that EIMT was being undertaken in an appropriate and timely manner in compliance with SL’s LC 28 arrangements. On a sample basis I verified that in instances where SNM(N) had decided to delay EMIT this was appropriately justified in line with the variation that SL had put in place to its LC 28 arrangements.
Evidence was inspected that confirmed those undertaking Control and Supervision activities had been appropriately appointed in line with SL’s Corporate arrangements for LC 12. Also that personnel undertaking operations and EIMT activities were trained in line with SL’s Corporate arrangements for LC 10.
On the basis of the remote intervention evidence sampled in relation to LC 10, 12 and 28 I did not identify any matters of concern. Consequently, I judged from the evidence sampled that SL has effectively implemented its arrangements for compliance with LCs 10, 12 and 28 across SNM(N) and I have assigned an inspection rating of Green (no formal action) for compliance against these LCs.