Office for Nuclear Regulation

Compliance inspection of Licence Conditions 7 (incidents on site) & 36 (organisational capability)

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 Sub Division. In accordance with that strategy, Licence Condition (LC) compliance inspections were carried out on the Magnox Operating Unit (OU), as planned. 

The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee’s formal arrangements for compliance with LC 7 (incidents on site) and LC 36 (organisational capability).

Interventions Carried Out by ONR

I carried out an on-site LC 7 compliance inspection of Magnox Reprocessing Facility (MRF) and a LC 36 compliance inspection of the Magnox East River (MER). The inspections comprised discussions with SL staff, review of records and sampling of electronic databases and other documentation.

 LC7 requires the licensee to make and implement adequate arrangements for the notification, recording, investigation, and reporting of incidents occurring on the site. As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:

LC 36 requires the licensee to provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site.  In carrying out this inspection, the following ONR guidance was used:

Explanation of Judgement if Safety System Not Judged to be Adequate

This was not a system based inspection and is therefore not applicable.

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

During the LC7 inspection, I sampled evidence associated with the licensee’s compliance with its formal arrangements for the review of incidents within MRF and examined a sample of SL’s incident screening and classification process to determine whether the licensee had encouraged a robust and effective level of self-challenge when considering its response to each of those incidents.

Additionally, I inspected the way SL tracks actions and trends root causes of incidents and, where appropriate, carries out reviews of the effectiveness of actions carried out. 

One minor shortfall was identified in relation to the adequacy of the recording of the justifications for when MRF have decided not to carry out investigations and this will be followed up as a Level 4 regulatory issue as part of routine regulatory business. Notwithstanding this minor shortfall; on the basis of my sample, I consider that the licensee has adequately implemented their arrangements in place for LC7.   Therefore, I judge that an inspection rating of Green (No Formal Action) is merited.

During the LC36 inspection, I sampled evidence relating to the provision of adequate human resources within the MER.  I focused on the identification of resources important to safe operation, effectiveness of controlling changes that might impact on safety and any incidents where resource availability could impact the safety of operations within the Operating Unit.

On the basis of my sample, I consider that the licensee has adequately implemented their arrangements in place for LC36. Therefore, I judge that an inspection rating of Green (no formal action) is merited.

From the areas sampled, I did not identify any shortfalls in the implementation of the licensee’s arrangements which would necessitate a further inspection of those arrangements earlier than currently planned. 

Conclusion of Intervention

From the evidence sampled during these inspections, I judge that there was sufficient evidence to conclude that the licensee’s formal arrangements for compliance with Licence Condition 7 and 36 are being implemented adequately within the Magnox operating unit and inspection ratings of Green (no formal action) were merited. The rationale for this decision was discussed with the licensee and the decision was accepted.