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 licence condition inspection was performed to assess Utilities’ compliance with Sellafield Ltd’s (SL) corporate arrangements for various Licence Conditions. These included Licence Condition (LC) 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 26 (Control and supervision of operations) and LC 28 (Examination, inspection, maintenance and testing). 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 (Coronavirus) 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. A specific purpose of this licence condition compliance inspection was to determine whether or not the flexibility allowed by the variations relevant to LC 10, LC 12 and LC 28 arrangements had needed to be utilised by Utilities and, if it had, whether the varied arrangements had been complied with.
This compliance inspection was carried out against a range of LCs including LC10 (Training), LC12 (Duly authorised and other suitably qualified and experienced persons), LC26 (Control and supervision of operations), and LC28 (Examination, inspection, maintenance and testing).
The intervention commenced with a question and answer teleconference at which supporting evidence was requested. A desktop review of the evidence was undertaken followed by a subsequent clarification teleconference. Judgements were made based on the adequacy of the assurances provided and supporting documentary evidence.
Not applicable since this was not a safety system based inspection.
Assurance was provided that Utilities understands the SL corporate arrangements for compliance with the identified LCs and that the arrangements are being appropriately complied with. In addition, assurance was provided that SL is considering appropriate mitigation for possible increased challenges regarding availability of Utilities’ personnel during the COVID-19 (Coronavirus) pandemic.
The underpinning evidence for some aspects of the assurances received from SL was tested during the intervention. This included evidence that Utilities had not yet needed to use the flexibility allowed by the variations relevant to its LC 10 and LC 12 arrangements. The assurances received in relation to LC10, 12 and 26 were sufficient to judge that there were no matters identified that would warrant formal follow-up.
Evidence that examination, inspection, maintenance and testing was being undertaken in an appropriate and timely manner in compliance with SL’s LC 28 arrangements was inspected. On a sample basis it was verified that, in instances where Utilities had decided to delay maintenance, this was deferred in line with the variation that SL has put in place to its LC 28 arrangements.
Assurance was provided regarding how Utilities is complying with SL’s arrangements for LC 10, 12 and 26. The assurance was sufficient to judge that there were no matters identified that would warrant formal follow-up.
The evidence sampled in relation to LC 28 did not identify any matters of concern. It was judged that it was appropriate to rate compliance against the SL corporate arrangements for LC 28. From the evidence sampled during the inspection, it is considered that SL has effectively implemented its arrangements for compliance with LC 28 across Utilities and an inspection rating of Green (no formal action) is considered to be appropriate.