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LC12 and 26 compliance inspection - Package Management and Railways

  • Site: Sellafield
  • IR number: 19-054
  • Date: September 2019
  • LC numbers: 12, 26

Executive summary

Purpose of Intervention

ONR undertakes planned regulatory inspections at Sellafield, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2019/20 identifies the Licence Conditions (LCs) that will be inspected over this period.

This planned inspection was undertaken to determine if SL’s Package Management and Railways (PM&R) is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition12  (Duly authorised and other suitably qualified and experienced persons), and Licence Condition 26 (Control and supervision of operations).  PM&R provides a number of important roles (e.g. flask maintenance, transportation of radioactive materials) that support the safety of Sellafield’s site-wide operating facilities, including its high hazard and risk reduction work. 

The overall adequacy of SL's site-wide LC12 and 26 arrangements are considered separately in other ONR inspections.

Interventions Carried Out by ONR

Licence Condition 12 (LC12) requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect safety of operations on the site or any other duties assigned by or under these conditions or any arrangements required under these conditions.

Licence Condition 26 (LC26) requires the licensee to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by the licensee. 

My inspection comprised discussions with staff, examination of plant documentation, and inspection of the facility equipment that focussed on SL’s Oxide Flask Maintenance Facility, specifically:

  • arrangements that define and set out operations that may affect safety
  • arrangements that define posts for the control, and supervision of operations
  • arrangements that define, establish, and appoint a Duly Authorised Person
  • arrangements that demonstrate a Duly Authorised Person is suitable qualified and experienced
  • Implementation of learning from related incidents on site 

Explanation of Judgement if Safety System Not Judged to be Adequate

Not applicable; this was not a safety system based inspection.

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

There were no significant findings identified during this inspection.

SL’s Package Management and Railways organisation demonstrated an adequate understanding of the site-wide LC12 and 26 arrangements. Overall, I consider that SL’s Package Management and Railways organisation has adequately implemented its arrangements for compliance with LC12 and 26.  Indeed, the implementation is good in several areas, for example its arrangements for the management and control of sealed sources.   However, there were also some minor areas for improvement identified, for example SL’s On-line People Management System configuration and ability to access data.

Conclusion of Intervention

As I found no significant shortfalls, on balance, I consider an inspection rating of Green (no formal action) is merited against both LC12 and LC26 as a result of this inspection.

My findings were shared with and accepted by the licensee as part of normal inspection feedback.