Office for Nuclear Regulation

Compliance inspection of Licence Conditions 10, 12 and 26

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR) 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.

This record describes the outcome from a planned compliance inspection at the Pile Fuel Storage Pond (PFSP) facility on the Sellafield Site. This intervention targeted PFSP as it is a high hazard facility and its continued safe operation during the COVID-19 pandemic is key for continued nuclear safety of the Sellafield site. The purpose of the inspection was to inspect Sellafield Limited (SL) against compliance with its corporate arrangements for Licence Conditions (LC): 10 (Training); 12 (Duly authorised and other suitably qualified and experienced persons (SQEP)) and 26 (Control and supervision of operations).

The intervention involved an inspection of the facility followed by a review of evidence with the appropriate members of the Licensee organisation, noting the limitations in place, at the time, as a result of the coronavirus (COVID-19) pandemic. The inspection has been carried out in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the coronavirus situation. At the time of this intervention PFSP operations had returned to near pre-Covid-19 levels, with the introduction of Covid-19 social distancing measures which were inspected as part of the visit.

In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations 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, 12 and 26. Prior to this intervention, ONR has reviewed the relevant variations and is satisfied that they are adequate. This inspection has included consideration of whether the variations have been used at PFSP, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection was carried out against LCs 10, 12, and 26, it sought to seek evidence of compliance in each case. The inspections against LCs 10, 12 and 26 were linked by consideration of a common theme associated with maintaining Minimum Safe Manning Levels (MSML).

The inspection involved discussions with several individuals from the PFSP facility: the head of operations, the operations manager, the Shift Team Manager (STM), the Shift Team Leader (STL) and a control room operator. This was followed by a review of evidence of training and qualification between the ONR inspector, the SL Nuclear Intelligence & Independent Oversight (NI&IO) internal regulator and representatives from PFSP and the Sellafield training department. This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session as it was not accessible at the time of the inspection. The inspection concluded with a de-brief with the head of operations for PFSP.

Explanation of Judgement if Safety System Not Judged to be Adequate

This section is not applicable.

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

In relation to LC 10 and LC 12, the inspection focussed on training and demonstration of competence for operations associated with safety at the PFSP complex.  I found that compliance with SL’s corporate arrangements was being maintained and that there had only been limited application of the COVID-19 variations to SL’s corporate arrangements affecting these LCs. Nonetheless, I found some minor areas for improvement in relation to training as such I have raised a Level 4 Regulatory Issue (the lowest level) for SL to address.

In relation to LC 26, the inspection focussed on PFSP’s control and supervision of operations and found that compliance with SL’s corporate arrangements was being maintained and the facility had only made limited use of the COVID-19 variations to SL’s corporate arrangements affecting this LC.

In relation to COVID-19 safety, I found the measures which had been put in place by PFSP to be robust and they had been developed by the personnel based on the facility to ensure ownership and greater adherence to the new arrangements.

Conclusion of Intervention

The LC 10, LC 12 and LC 26 compliance inspection concluded that the licensee had adequately implemented its arrangements. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited here for the PFSP facility on the Sellafield Site for each of these licence conditions.

In the case of LC 10, a Level 4 Regulatory Issue has been agreed with SL to track SL’s progress in addressing shortfalls relating to PFSP’s training of operational personnel.