Office for Nuclear Regulation

Sellafield 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 Subdivision. 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 28 (Examination, inspection, maintenance and testing).

Interventions Carried Out by ONR

I carried out an on-site LC 28 compliance inspection of Magnox Reprocessing Facility (MRF). The inspections comprised discussions with SL staff, review of records and sampling of electronic databases and other documentation.

 LC28 requires the licensee to make and implement adequate arrangements for the regular and systematic examination, inspection, maintenance and testing of all plant which may affect safety. As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation 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 LC28 inspection, I sampled evidence associated with the licensee’s compliance with its formal arrangements for EIMT within MRF and examined a sample of MRF’s safety mechanisms identified in the safety case through the planned maintenance system. I was satisfied that the facility had followed their formal arrangements for LC28 and had derived a planned maintenance schedule that was aligned with safety case requirements.

I reviewed the systems in place to monitor the planned maintenance schedule to ensure that EIMT was carried out as required and the non-delivery process that was applied to those that could not be delivered on time. I was satisfied that the facility had followed their formal arrangements for delivery and non-delivery of EIMT.

Additionally, I also sought and received assurance that MRF understands the EIMT backlog as a result of the non-delivery process during the Covid-19 lockdown period and judge that MRF are adequately deploying resources to deliver this maintenance in a timely manner.

Two minor shortfalls were identified in relation to justification for non-delivery of maintenance and retention of maintenance records. These will be followed up as Level 4 regulatory issues as part of routine regulatory business. Notwithstanding these minor shortfalls; on the basis of my sample, I consider that the licensee has adequately implemented their arrangements in place for LC28.   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 28 is being implemented adequately within the Magnox Reprocessing Facility and an inspection rating of Green (no formal action) was merited. The rationale for this decision was discussed with the licensee and the decision was accepted.