Office for Nuclear Regulation

Compliance inspection of Licence Condition 22

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).

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 22 (modification or experiment on existing plant).

Interventions Carried Out by ONR

LC 22 requires that the licensee implements adequate arrangements to control any modification or experiment carried out on any part of the existing plant which may affect safety.  On 9th December 2020, I carried out a planned, one-day, on-site LC 22 compliance inspection within Magnox East River (MER). The inspection comprised discussions with SL staff and reviews of plant records and other documentation.  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 therefore no judgement has been made of the adequacy of implementation of any part of the safety case.

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

During the LC22 Inspection, I sampled evidence associated with the licensee’s compliance with its arrangements for control of modification to existing plant and reviewed whether the licensee is considering all modifications to those facilities in a manner proportionate to the risks posed by such changes. 

I reviewed the systems in place to monitor the Plant Modification Proposals (PMP) and was satisfied that the facility is maintaining an overview and managing the open PMPs. Additional I reviewed a selection of PMPs and was satisfied that the facility had followed the SL procedures for categorisation, approval and completion of the PMP process.

I sampled the training records for several PMP Managers and PMP Chairpersons and was satisfied that these were completed and in date.

I examined evidence of the control of Temporary Plant Interventions (TPI) on the facility and found the completion and approval of the TPIs to be in line with the SL procedures. A minor shortfall was identified in relation to the number of TPIs that had exceeded the 1 year close out date. This will be followed up through a Level 4 regulatory issue as part of routine regulatory business.

Notwithstanding the minor shortfall above; on the basis of my sample I consider that the licensee has adequately implemented their arrangements in place for LC 22.  Therefore, I judge that an inspection rating of Green (no formal action) is merited.

From those areas sampled, I did not identify any significant shortfalls in the licensee’s formal arrangements for compliance with LC 22 which would prompt a further inspection of those arrangements earlier than currently planned.

Conclusion of Intervention

From the evidence sampled during this inspection, I judge that the licensee’s formal arrangements for compliance with Licence Condition 22 are being implemented adequately and an inspection rating of Green (no formal action) is merited.