The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2020/21, updated as a result of the COVID-19 Pandemic, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with LC 10 (Training), LC 12 (Duly authorised and other suitably qualified and experienced persons), LC 24 (Operating Instructions), LC 26 (Control and supervision of operations) and LC 28 (Examination, Inspection, Maintenance and Testing) on Encapsulation Plant, focusing on the restart activities for Magnox Encapsulation Plant (MEP).
The overall adequacy of SL's site-wide LC compliance arrangements is considered separately in other ONR interventions.
I carried out planned remote LC 10, 12, 24, 26 and 28 compliance inspections of Encapsulation Plant. The inspection focused on the evidence supporting readiness for restart of active operations at MEP after the forced outage in response to the COVID19 pandemic. The following areas were sampled:
The inspection comprised remote document review in advance of discussions with SL staff and review of records requested during telephone meetings. SL’s internal regulator was in attendance for the duration of the inspection.
Not applicable since this was not a safety system based inspection.
No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 10, LC 12, LC 24, LC 26 and LC 28 arrangements at Encapsulation plant. At the time of the inspection no evidence that a review of the impact of deferral of emergency exercises and drills had been conducted was available. A level 4 issue has been raised to ensure that this is made provided to ONR to sample outside of this intervention. A minor shortfall with respect to DAP sign off of maintenance of Safety Mechanisms will be followed up by the SL internal regulator.
My findings were shared with, Encapsulation Plant management as part of normal inspection feedback.
On the basis of the evidence sampled at the time of the inspection, I judge that Encapsulation Plant has adequately implemented SL’s arrangements for LC 10, LC 12, LC 26, and LC 28. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited.
As a result of the extended period of shutdown the sample achieved with respect to LC 24 was not sufficient to provide a formal rating. However, assurance of compliance was gained and no significant shortfalls identified.
A level 4 regulatory issue has been raised to facilitate tracking of review and revision to LC11 emergency exercises and drills that was not available at the time of the inspection.