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 Security & Resilience’s compliance with Sellafield Ltd’s (SL’s) 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 11 (Emergency arrangements) 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 Security & Resilience, and, if it had, whether the varied arrangements had been complied with. During the inspection, SL provided an Agreement for Variation for LC11 relating to Topic Area 2.02 Emergency Management (Drills and Exercises). In contrast to variation documents associated with LCs 10, 12 & 28, which have already been received and reviewed by ONR, this had not been. Assessment of the adequacy of this variation will be undertaken outside of the scope of this inspection.
This compliance inspection was carried out against a range of LCs including LC 10 (Training), LC 11 (Emergency arrangements), LC 12 (Duly authorised and other suitably qualified and experienced persons) and LC 28 (Examination, inspection, maintenance and testing).
The intervention commenced with a question and answer teleconference at which evidence received prior to the intervention was discussed and further 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 Security & Resilience understands the SL corporate arrangements for compliance with the identified LCs and that the arrangements, where possible, are being appropriately complied with. In addition, assurance was provided that where Security & Resilience are unable to comply with SL corporate arrangements owing to the COVID-19 (Coronavirus) pandemic, the flexible arrangements provided by the variations relevant to its arrangements were being appropriately complied with. Assessment of the adequacy of the Agreement for Variation for LC11 relating to Topic Area 2.02 Emergency Management covering Emergency Drills and Exercises will be undertaken outside of the scope of this inspection.
The underpinning evidence for some aspects of the assurance received from SL was tested during the intervention. This included evidence that Security & Resilience were conducting drills and exercises by remote means and that those individuals with designated roles within the Emergency Duty Teams were having their competence maintained/assessed through professional discussions in line with social distancing requirements. The assurances received in relation to LC 10, 11 and 12 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. Some areas for improvement were identified in the justification of maintenance / operational check frequencies and the attention to detail regarding maintenance / operational check records. A Level 4 Regulatory Issue has been raised to track progress in these areas.
Assurance was provided regarding how Security & Resilience is complying with SL’s arrangements, or the flexible arrangements provided by the variations relevant to its arrangements, for LC 10, 11 and 12. The assurance was sufficient to judge that there were no matters identified that would warrant formal follow-up. From the evidence sampled during the inspection, it is considered that SL has effectively implemented its arrangements for compliance with these LCs across Security & Resilience and an inspection rating of Green (no formal action) is considered appropriate for each.
The evidence sampled in relation to LC 28 highlighted some areas for improvement and a Level 4 Regulatory Issue has been raised to capture these points, define actions and track SL’s progress in these areas. Notwithstanding these areas for improvement, it is considered that an inspection rating of Green (no formal action) is considered appropriate for LC 28.