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.
This planned intervention was undertaken to determine if the National Nuclear Laboratory’s (NNL’s) Central Laboratory (CL), is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 22. This facility was selected for inspection since it contains a significant inventory of nuclear and radioactive material, and the quantity of such material and associated scope of operations is likely to grow in the future. It is also anticipated that analytical services for the Sellafield site will transfer from another facility to the CL. It should be noted that although the facility is on the licensed site, and hence duties under the licence conditions rest with Sellafield Limited (SL), it is operated by NNL as a tenant.
This inspection sought assurance that NNL has adequate controls in place for modifications or experiments in the CL, and complies with SL’s site-wide arrangements for Licence Condition 22. The adequacy of SL’s site-wide arrangements more generally is considered in other inspections.
This was a joint nuclear safety and security inspection.
Licence Condition 22 (LC 22) requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.
My inspection, which comprised discussions with SL and NNL staff, examination of plant documentation, and interview with selected SQEPs, focussed on the following areas:
Not applicable; this was not a Safety System inspection.
I consider that NNL has adequate controls in modifications or experiments in the CL that may affect safety, and has broadly implemented the SL arrangements for compliance with LC 22.
This, however, follows NNL addressing the significant shortfalls identified by the joint Independent Assurance (IA) and Operations Control Manager (OCM) review of the Plant Modification Proposal (PMP) process in February 2021. Although some actions are still ongoing, I consider it has brought NNL in line with the SL arrangements for LC 22 compliance.
Although some PMPs have been overdue for a significant period of time potentially eroding confidence in configuration control, NNL has set itself a target to close out all currently overdue PMPs by September 2021, which I will closely monitor.
For these reasons, on balance, I consider the inspection merits an IIS rating of Green, (No Formal Action), against LC22.
From the discussions with NNL and SL and evidence sampled during the inspection, I consider that NNL has adequately implemented the SL arrangements for compliance with LC 22 in the Central Lab. I have assigned an inspection rating of Green (no formal action) to be appropriate for compliance against LC 22; modification or experiment on existing plant.