Office for Nuclear Regulation

Planned compliance inspection of Licence Condition 28

Executive summary

Purpose of Intervention

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 28 (Examination, inspection, maintenance and testing) (EIM&T) at the Thermal Oxide Reprocessing Plant (THORP).

The overall adequacy of SL's site-wide LC 28 arrangements is considered separately in other ONR interventions.

Interventions Carried Out by ONR

I, the Site Inspector for THORP, supported by a Fault Studies Inspector carried out planned LC 28 compliance inspections at THORP. The inspection focused on:

The inspection comprised discussions with SL staff, a review of records, and the sampling of information contained within electronic databases and other documentation.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since this was not a safety system based inspection.

Key Findings, Inspector's Opinions and Reasons for Judgements Made

No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the LC 28 arrangements at THORP. I found that THORP has adequately implemented the SL corporate arrangements for LC 28, including the SL COVID-19 variation for non-delivered items as THORP shutdown the majority of its operations as a result of the COVID-19 Pandemic. I also sought and received assurance that THORP understands the EIM&T backlog as a result of the non-delivery process and has plans and resources to deliver this maintenance prior to equipment being restarted.

One minor shortfall was identified in relation to the records related to the control and supervision of one EIM&T item and this will be followed up as a Level 4 regulatory issue as part of routine regulatory business. I recognised one area of good practice in relation to making a positive statement when a written instruction was deemed to be fit for purpose.

My findings were shared with, acknowledged and accepted by THORP’s management as part of normal inspection feedback.

Conclusion of Intervention

On the basis of the evidence sampled at the time of the inspection, I judge that THORP has adequately implemented SL’s arrangements for LC 28, with one minor shortfall identified. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is merited. One Level 4 (i.e. lowest level) regulatory issue has been raised to manage the resolution of the identified shortfall.