- Site: Sellafield
- IR number: 19-164
- Date: January 2020
- LC numbers: 19, 20
Executive summary
Purpose of Intervention
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, Licence Condition (LC) 19 (Construction or installation of new plant) and LC20 (Modification to design of plant under construction) Arrangements Inspections were carried out, as planned, at Hinton House, Risley on 28-30 January 2020.
The main purpose of these inspections was to determine whether the site-wide arrangements identified by SL against LC19 and LC20 adequately met the requirements of these licence conditions.
The purpose of LC19 and LC20 is to maintain the integrity of the design of new plant which may affect safety and thus compliance with its nuclear safety case during the construction or installation phase.
Whilst the main focus of this inspection was on SL’s LC19 and LC20 arrangements, SL also needs to comply with all the LCs and with the Health and Safety at Work etc. Act 1974 (HSWA 74) and its Relevant Statutory Provisions (RSPs) during construction or installation of new plant and when modifying the design of plant under construction. The inspection therefore considered in particular the interface of LC19 and LC20 arrangements with HSWA 74 and its RSPs, especially The Construction (Design and Management) Regulations 2015 (CDM 2015).
The inspections 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 intelligence gained from other ONR interventions.
Interventions Carried Out by ONR
The inspections were carried out by an SDFW Inspector, with support from a Nuclear Internal Hazards & Site Safety Inspector and the SDFW Thermal Oxide Reprocessing Plant (THORP) and Oxide Fuel Storage Group (OFSG) Site Inspector. A representative of SL’s Nuclear Intelligence & Independent Oversight (NI&IO) also participated.
The inspections focussed on the following areas:
- Determining if SL’s site-wide arrangements for compliance with LC19 and LC20 (including the adequacy of the record schedule) are adequate to meet the requirements of the relevant LC;
- Understanding the deployment status of SL’s site-wide arrangements for compliance with LC19 and LC20;
- Obtaining insights on the fitness-for-purpose of SL’s site-wide LC19 and LC20 arrangements from selected key role holders; and,
- Reviewing SL’s internal assurance activities relevant to its site‑wide LC19 and LC20 arrangements and SL’s state of learning from recent incidents related to these LCs.
In carrying out this inspection, the following ONR guidance was used:
- NS-INSP-GD-019 Revision 5, “LC19: Construction or Installation of New Plant”.
- NS-INSP-GD-020 Revision 5, “LC20: Modification to Design of Plant Under Construction”.
- NS-TAST-GD-057 Revision 5, November 2017, “Design Safety Assurance”.
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
Licence Condition 19
On the basis of the evidence sampled before and during this inspection, I (SDFW Inspector) consider that the key building blocks of adequate LC19 arrangements are in place. I identified six good practices and eight relatively minor deficiencies relating to SL’s site-wide LC19 arrangements.
Some of the noted deficiencies are expected to be addressed in the short term as part of SL’s ongoing work to improve its management system.
In addition, for some deficiencies, it will only be necessary to reference existing documents in the Sellafield Limited Management System into the LC19 compliance matrix to address the shortfall.
Because of these factors, I consider there to be relatively minor deficiencies in SL’s LC19 compliance arrangements as opposed to a significant failure to meet compliance arrangements.
Licence Condition 20
On the basis of the evidence sampled before and during this inspection, I consider that the key building blocks of adequate LC20 arrangements are in place. I identified five good practices and three relatively minor deficiencies relating to SL’s site-wide LC20 arrangements. The three deficiencies were similar, in the context of LC20, to three of the eight LC19 deficiencies noted earlier.
Some of the noted deficiencies are expected to be addressed in the short term as part of SL’s ongoing work to improve its management system.
In addition, for some deficiencies, it will only be necessary to reference existing documents in the Sellafield Limited Management System into the LC20 compliance matrix to address the shortfall.
Because of these factors, I consider there to be relatively minor deficiencies in SL’s LC20 compliance arrangements as opposed to a significant failure to meet compliance arrangements.
Conclusion of Intervention
For both LC19 and LC20 the NI&IO participant was broadly content with the outcomes of this inspection.
For both LC19 and LC20 the SL staff who were presented with the debrief were content with the inspection outcome, understand the issue raised and the proposed way forward.
Taking the above key findings into account I consider that an inspection rating of Green (No Formal Action) is merited for both LC19 and 20.
I have raised two Level 4 (the lowest level) Regulatory Issues to log and track progress against the minor deficiencies identified relating to SL’s LC19 and LC20 arrangements.