Office for Nuclear Regulation

Compliance inspection of Licence Conditions 27 and 28

Executive summary

Purpose of Intervention

In accordance with the Office for Nuclear Regulation’s (ONR’s) 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.  The inspection was undertaken in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the COVID-19 pandemic.  

This record describes the outcome from a planned compliance inspection at the First Generation Magnox Storage Pond (FGMSP) facility on the Sellafield Site. This intervention targeted FGMSP 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 confirm Sellafield Limited’s (SL) compliance with its corporate arrangements for Licence Conditions (LC): 27 (Safety Mechanisms, Devices and Circuits); and 28 (Examination, Inspection, Maintenance and Testing).

The inspection began with a review of evidence with the appropriate members of the Licensee organisation and then an inspection of the facility, noting the limitations in place, at the time, as a result of COVID-19. At the time of this intervention FGMSP operations had returned to near pre-COVID-19 levels and the measures in place associated with the pandemic were also subject to inspection.

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 27 and 28. 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 FGMSP, and if so, whether they have been complied with.

Interventions Carried Out by ONR

This inspection sought evidence of compliance against LCs 27 and 28 and were linked by consideration of a common theme of SL’s ability to maintain the safety case designated Safety Mechanisms, Devices and Circuits (SMDCs) despite the restrictions associated with the COVID-19.

The inspection began with the examination of evidence with representatives from FGMSP Engineering and the Legacy Ponds followed by an inspection of the facility. The inspection concluded with a de-brief with the Engineering Manager for Legacy Ponds and lead team.

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 27, the inspection focussed on examination of evidence that the equipment had been identified in the extant safety case, those requirements had been accurately implemented and the physical condition of the SMDCs was adequate. I found that compliance with SL’s corporate arrangements was being maintained and that there had only been limited application of a COVID-19 variations to SL’s corporate arrangements affecting this LC.

In relation to LC 28, the inspection focussed on FGMSP’s examination of evidence that the equipment identified in the extant safety case was being maintained and those maintaining the equipment were Suitably Qualified and Experienced Persons (SQEP).  I found that compliance with SL’s corporate arrangements was being maintained. In addition, the inspection found that the facility had needed to make limited use of a COVID-19 variations to SL’s corporate arrangements affecting this LC. Nonetheless, I found some minor areas for improvement in relation to training and appointment of SQEP maintenance personnel, as such I have raised a Level 4 Regulatory Issue (the lowest level) for SL to address.

In relation to social distancing measures, I found the measures implemented by FGMSP were robust. I It was noted that the plant personnel developed the arrangements to ensure operations could continue with minimal disruption.

Conclusion of Intervention

The LC 27 and LC 28 compliance inspection concluded that the licensee had adequately implemented its arrangements for the aforementioned Licence Conditions. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited.

In the case of LC 28, a Level 4 Regulatory Issue has been agreed with SL to track SL’s progress in addressing shortfalls relating to FGMSP’s training and appointment of SQEP maintenance personnel.