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.
This record describes the outcome from a planned compliance inspection at the First Generation Magnox Storage Pond (FGMSP) facility on the Sellafield Site. This intervention targeted FGMSP as it is a high hazard facility and its continued safe operation during the COVID-19 pandemic is key for continued nuclear safety of the Sellafield site. The purpose of the inspection was to confirm Sellafield Limited’s (SL) compliance to its corporate arrangements for Licence Conditions (LC): 10 (Training); 12 (Duly authorised and other suitably qualified and experienced persons (SQEP)) and 26 (Control and supervision of operations).
The inspection was carried out using a blended approach which began with an inspection of the facility and then a review of evidence remotely, noting the limitations in place, at the time, as a result of the coronavirus (COVID-19) pandemic. The inspection has been carried out in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the coronavirus situation.
In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations 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, 12 and 26. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. This inspection has included consideration of whether the variations have been used at FGMSP, and if so, whether they have been complied with.
This inspection was carried out against LCs 10, 12, and 26. It sought to seek evidence of compliance in each case. 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. The inspections against LCs 10, 12 and 26 were linked by consideration of a common theme, Minimum Safe Manning Level (MSML).
The inspection began with a facility visit and discussion with a number of individuals from the FGMSP facility: the head of operations, the deputy operations manager, the Shift Team Coordinator (STC), the Shift Team Manager (STM) and three control room operators. This was supplemented by a question and answer teleconference between the ONR inspector, the SL Nuclear Intelligence & Independent Oversight (NI&IO) internal regulator and representatives from FGMSP. This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session and in some cases clarifications were sought by separate phone calls. The inspection concluded with a follow-up teleconference. Regulatory judgements have been made based on the verbal answers and supporting documentary evidence.
This section is not applicable.
In relation to LC 10 and LC 12, the inspection focussed on training and demonstration of Suitably Qualified and Experienced Persons (SQEP) for operations associated with the defining the MSML. I found that compliance with SL’s corporate arrangements was being maintained. In addition, the inspection found that the facility had needed to make limited use of a COVID-19 variations to SL’s corporate arrangements affecting these LCs. Nonetheless, I found some areas for improvement and as such I have raised a Regulatory Issue for the Licensee to review any training requirements which have been specified in documentation and ensure these requirements are appropriately planned and delivered including any additional training requirements
In relation to LC 26, the inspection focussed on FGMSP’s control and supervision of operations and found to be in line with SL’s LC 26 arrangements. I found that compliance with SL’s corporate arrangements was being maintained. In addition, the inspection found that the facility had needed to make limited use of a COVID-19 variations to SL’s corporate arrangements affecting these LCs. Nonetheless, I found some areas for improvement and as such I have raised a Regulatory Issue for the Licensee to review MSML requirements which have been specified in the documentation and ensure these requirements can be met in all reasonably conceivable scenarios.
The LC 10, LC 12 and LC 26 compliance inspection concluded that the licensee had adequately implemented its arrangements for the aforementioned Licence Conditions. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here for the FGMSP facility on the Sellafield Site for each of these licence conditions.
In the case of LC 10 and LC 26, for each, a Level 4 Regulatory Issue has been agreed with SL to track SL’s progress in addressing shortfalls relating to FGMSP’s training and MSML resilience.