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 Analytical Services’ compliance with Sellafield Ltd’s (SL’s) corporate arrangements for LC 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 23 (Operating Rules), LC 26 (Control and supervision of operations) and LC 28 (Examination, inspection, maintenance and testing (EIMT)).
The intervention was undertaken remotely from site due to the restrictions in place during the current COVID-19 (Coronavirus) pandemic. The inspection has been carried out in line with the ONR Sellafield, Decomissioning, Fuel and Waste Division’s regulatory approach to the COVID-19 situation.
In response to the pandemic, 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 Analytical Services was compliant with SL arrangements including with any variations Analytical Services had decided to utilise.
This inspection was carried out against LCs 10, 12, 23, 26 and 28. It sought to seek evidence of compliance in each case. However, it was recognised that given the remote nature of the intervention, a formal judgement of compliance would only be made should a sufficiently-sized sample of evidence be available under the circumstances. In this case, it was decided that a formal compliance rating was only possible against LCs 10, 12, 23 and 28.
The inspection began with question and answer teleconference between the inspection team, representatives from Analytical Services and the SL Nuclear Intelligence & Independent Oversight (NI&IO) internal regulator. This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session. The inspection concluded with follow-up teleconferences. Regulatory judgements have been made based on the verbal answers and supporting documentary evidence.
N/A as this was not a System Based Inspection.
Assurance was provided that Analytical Services understands the corporate SL arrangements for compliance with the identified LCs and that the arrangements are being appropriately complied with. In addition, assurance was provided that Analytical Services has taken appropriate steps to ensure adequate manning and supervision within the facility while meeting site demand requirements during the COVID-19 pandemic.
As a result of the reduced operations taking place in Analytical Services, during the COVID-19 pandemic, no activities have taken place that could challenge the limits of the safe operating envelope of the facility. Consequently, there has been no requirement to record compliance with those limits and conditions because no fissile movements have taken place. Nevertheless, the inspection found that Analytical Services has been recording material movements and has been maintaining routine plant surveillance against its safe operating envelope.
The inspection team found that examination, inspection, maintenance and testing (EIMT) is being undertaken in an appropriate and timely manner. On a sample basis it was verified that where Analytical Services has delayed EIMT it has made appropriate use of corporate processes and that non-delivery was appropriately justified.
On the basis of the remote intervention evidence sampled at Analytical services in relation to LCs 10, 12, 23 and 28, the inspection team judged that the licensee had effectively implemented its arrangements for compliance with these licence conditions and has assigned an inspection rating of GREEN (no formal action required).
The inspection team judged that there was an insufficiently sized sample of evidence to underpin an inspection rating against LC 26. However, assurance was provided regarding how Analytical Services was complying with SL arrangements and no matters were identified that would require formal follow-up.