- Site: Sellafield
- IR number: 19-111
- Date: October 2019
- LC numbers: 34
Executive summary
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited (SL), against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, a Licence Condition (LC) 34 (Leakage and Escape of Radioactive Material and Radioactive Waste) arrangements Inspection was carried out, as planned, on 9, 10 and 11 October 2019.
The main purpose of the inspection was to determine whether the site-wide arrangements identified by SL against LC34 adequately met the requirements of the licence condition.
The Inspection comprised discussions with SL staff and reviews of a targeted sample of SL’s documentation. The scope and priorities of the inspection took into account trends in reported incidents and intelligence gained from other ONR interventions.
Interventions Carried Out by ONR
The inspection was carried out by an SDFW Inspector, with support from two Nuclear Liabilities Regulation (NLR) Specialist Inspectors and an Environment Agency Senior Nuclear Regulator. A member of SL’s Nuclear Independent Oversight (NIO) also participated.
The inspection focussed on the following areas:
- The extent and deployment status of SL’s site-wide arrangements for compliance with LC34;
- Experience of application of the site-wide LC34 arrangements, at a cross section of plants where LC34 is important, by selected role holders;
- Records made to demonstrate compliance with LC34;
- SL’s means of gaining internal assurance of compliance with its site-wide LC34 arrangements;
- SL’s state of learning from recent incidents related to LC34; and,
- How SL’s LC34 arrangements integrate into the totality of SL’s arrangements to manage radioactive material, radioactive waste and nuclear matter.
ONR’s expectations in Nuclear Safety Technical Inspection Guide NS-INSP-GD-034 Revision 5, ‘LC34: Leakage and Escape of Radioactive Material and Radioactive Waste’ formed the main basis of the Inspection.
Given the cross-cutting relevance of containment of radioactive materials and radioactive wastes to several aspects of legal compliance at Sellafield, the inspection also considered the integration of the arrangements made by SL for the purposes of LC34 and those for other LCs (e.g. Licence Condition 35 “Decommissioning”) and broader legislative requirements (e.g. the Ionising Radiations Regulations 2017).
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable, as this was not a System Based Inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
On the basis of the evidence sampled before and during this inspection, I (SDFW Inspector) identified six areas of good practice.
On the basis of the evidence sampled before and during this inspection, I identified three minor shortfalls related to SL’s LC34 arrangements. These have been logged and progress will be monitored by two Level 4 (the lowest level) Regulatory Issues.
On the basis of the evidence sampled before and during this inspection, I identified one potential future minor shortfall related to SL’s LC34 arrangements. I have agreed a way forward with this matter with SL.
On the basis of the evidence sampled before and during this inspection, I identified three minor shortfalls relating to SL’s wider management system that were relevant to LC34 arrangements but required a broader scope of response from SL due to impacts for other areas such as Licence Condition 28 “Examination, inspection, maintenance and testing” and LC35. I have agreed a way forward with each of these matters with SL.
This intervention was performed in line with ONR’s internal instructions and guidance (primarily the Technical Inspection Guides).
Conclusion of Intervention
Taking the above key findings into account I consider that an inspection rating of Green (No Formal Action) is merited, based on ONR’s Inspection Rating Guide.
ONR has raised two Level 4 Regulatory Issues to log and track progress against the minor shortfalls identified.
The Environment Agency’s support of this Inspection addresses commitments under LC34 to interface with relevant environment agencies; gaining confidence and assurance in SL’s arrangements and their implementation.