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Sellafield - LC22 compliance inspection - EDNUP Project

  • Site: Sellafield
  • IR number: 19-109
  • Date: October 2019
  • LC numbers: 22

Executive summary

The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL), the site licensee, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.  The planned inspection schedule for the current regulatory year (covering April 2019 – March 2020), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.

This planned inspection was undertaken to determine if SL Electrical Distribution Network Upgrade Project (EDNUP) is adequately implementing the licensee’s site-wide arrangements for compliance with Licence Condition 22 (Modification or experiment on existing plant).  This project was selected as the target for this inspection as it is a major, multi-year development and provides a significant upgrade in the SL site’s electrical infrastructure.  The site electrical system is an important element of the site’s utility infrastructure and it supports the safety of Sellafield site-wide operating facilities, including its high hazard and risk reduction work.

The overall adequacy of SL's site-wide LC22 arrangements is considered separately in other ONR inspections.

Interventions Carried Out by ONR

LC22 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 affect safety.

My inspection, which comprised discussions with staff, examination of plant documentation, and inspection of training evidence, focussed on SL’s arrangements to:

  • Manage and control modifications.
  • Categorise, define hold points and close out modifications.
  • Define a Structure, System, or Component (SSCs) safety function and reliability requirement.
  • Establish adequate auditable and timely records.

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

The licensee demonstrated some areas of good practice, and I identified some minor areas for improvement that were accepted by the licensee.

I consider the implementation of the licensee’s arrangements for LC22 relating to the EDNUP scheme is good in several areas.  For instance, the licensee demonstrated a good understanding of the recently revised site-wide arrangements and training for Plant Modifications Proposals (PMP) and has adequately implemented them locally as part of its organisation arrangements.  SL’s Infrastructure Utilities organisation has demonstrated a proactive approach by significantly reducing the number of open plant modification proposals, and has established and implemented a transparent reporting arrangement.  Minor opportunities for further improvement were identified and the licensee provided assurance that it would address these minor shortfalls.

Conclusion of Intervention

During this inspection I found no significant shortfalls and therefore I consider an inspection rating of Green (no formal action) is merited against LC22 as a result of this inspection.

My findings from this inspection were shared with and accepted by the licensee as part of normal inspection feedback.  SL agreed that this was an effective and useful inspection.

No Regulatory Issues were raised as a result of this inspection.