Office for Nuclear Regulation

Compliance inspection of LC35 and EIADR at Calder Hall

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 selection of Calder Hall was driven by the planned acceleration in decommissioning and dismantling activities on site as part of the Calder Hall Land Clearance Project to make an area of the site currently housing Turbine Hall A and adjacent buildings available for re-development.

The purpose of this inspection was for ONR to determine the adequacy of the implementation of SL’s arrangements for compliance with LC 35 (Decommissioning), and with the Nuclear Reactors (Environmental Impact Assessment for Decommissioning) Regulations 1999, as amended (EIADR), at Calder Hall. 

Interventions Carried Out by ONR

The inspection was carried out against ONR’s expectations for LC 35 and EIADR. ONR sought sufficient evidence of compliance to allow an inspection rating to be allotted in each case.

Due to the current coronavirus (COVID-19) pandemic, the intervention followed a blended approach involving a mixture of remote engagement supplemented by an on-site inspection by the ONR Site Inspector for the Remediation Value Stream. The inspection was carried out in line with the ONR SDFW Division’s regulatory approach to the COVID-19 pandemic and relevant COVID-19 risk assessments.

The inspection began with a teleconference between the inspection team, representatives from Calder Hall, SL’s Process Owner for LC 35 and the internal regulator, Nuclear Intelligence & Independent Oversight (NI&IO). This session was supported by evidence that had been requested in advance of the meeting. Further evidence was requested and provided by SL following this session. The inspection concluded with a visit to site by the Remediation Value Stream Site Inspector and follow-up teleconferences involving the whole inspection team to provide hot feedback. Regulatory judgements have been made based on the verbal answers provided, the observations made on the site visit and the sampling of evidence provided by the licensee.

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable since this was not a System-Based Inspection.

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

No significant matters were identified that required immediate regulatory attention. However, a number of minor shortfalls (Level 4 Regulatory Issues) identified against the licensee’s arrangements for EIADR and the implementation of arrangements for LC 35 and EIADR at Calder Hall.

ONR acknowledged that SL has aspirations for a reduced timescale for decommissioning Calder Hall, consistent with the international and UK standards and therefore considered to be a good practice. ONR also noted that Calder Hall had proactively engaged with SL’s Central POCO Group and Problematic Waste Team to ensure consistency with these key enterprise-level functions. In addition to this, ONR noted that the sharing of information on relevant good practice and OPEX on decommissioning between Calder Hall, and Magnox Limited, had recently improved and will help support decommissioning activities moving forward.

From an EIADR perspective, SL had adequate arrangements in place for identifying changes to the decommissioning project and for undertaking a screening assessment to identify potential significant adverse effects on the environment as a result of those changes, as required by Regulation 13 of EIADR. ONR also acknowledged that SL was open and transparent regarding the shortfalls in its corporate arrangements and were keen to make progress in resolving this issue.

Conclusion of Intervention

On the basis of the sampled evidence and observations made during the site visit, the inspection team judged that Calder Hall had achieved an adequate level of compliance with ONR’s expectations in respect of LC 35 and EIADR.

ONR identified a number of minor shortfalls that were captured in Level 4 Regulatory Issues (the lowest level) that will be followed up as part of routine regulatory business.  No significant matters were identified that required immediate regulatory attention and hence an inspection rating of Green (no formal action) was merited.