- Site: Sellafield
- IR number: 19-181
- Date: February 2020
- LC numbers: 15
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield Site Licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The strategy requires inspections to be performed against Licence Condition 15 relating to Periodic Safety Reviews (PSR). LC15 requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases.
The purpose of this intervention was for ONR to sample and inspect the PSR for the Special Nuclear Materials (SNM) Legacy Storage facility (Stores 1 – 3) and to gain confidence that SL is taking the necessary steps to continue to operate and maintain the facilities in a manner that ensures that the plant risks are as low as reasonably practicable (ALARP).
The three broad objectives of this intervention were to:
- Gain confidence that SL has undertaken an adequate PSR, which takes into account lessons learnt and future foreseeable challenges;
- Gain confidence that the extant facility arrangements and the safety case are suitable and sufficient, and mitigate shortfalls awaiting improvements;
- Establish if SL has credible resolution plans to implement improvements identified by the PSR.
The inspection also provided an opportunity for ONR to gather information on the storage facility and the contribution that the plant could make to ONR’s strategic priority at Sellafield (high hazard risk reduction).
Interventions Carried Out by ONR
ONR carried out a one and a half day LC 15 compliance inspection of the SNM Legacy Storage facility (Stores 1 – 3) over 27-28 February 2020. The ONR inspection team consisted of a Leadership and Management for Safety inspector, Civil Engineering inspector, Chemistry inspector and a PSR Project inspector. Each ONR inspector reviewed the PSR and developed topics to inspect with SL:
- PSR process and shortfalls management;
- Safety case;
- Engineering and Operations;
- Leadership and Management for Safety (LMfS).
The intervention comprised of:
- Sampling the process and technical aspects of the application of SL PSR arrangements and associated documents;
- Discussions with appropriate members of SL staff with reference to the identified topics;
- A facility walk-down of the storage buildings. ONR was accompanied on the walk down by the Operations Manager, a Duly Authorised Person (DAP) and a System Engineer.
LC 15 requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases. The following ONR guidance was used:
- NS-INSP-GD-015, Revision 4, Periodic Review;
- NS-TAST-GD-050, Revision 7, Periodic Safety Reviews (PSR);
- ONR Safety Assessment Principles (SAP), 2020.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system based inspection; therefore no judgement has been made on the adequacy of the implementation of any specific part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
From the evidence sampled, ONR judges that SL has complied with requirements of LC 15 in carrying out a review and reassessment of safety of the SNM Legacy Storage facility (Stores 1 – 3). ONR identified three minor compliance shortfalls in relation to the PSR recommendations, ageing management and justification for re-purposing of stores which will be followed up as three Level 4 (i.e. lowest level) Regulatory Issues (RIs).
Notwithstanding the minor compliance shortfalls identified above the inspection did not reveal any matters of substantive concern that had not already been identified by SL as part of its own review or were already being progressed as part of its routine business. Closure of the shortfalls identified will be monitored by the ONR PSR inspector as part of normal, post inspection duties.
As part of its LC 15 arrangements SL will produce a Confirmation of Safety Letter to confirm that the facility has adequately implemented the PSR and that risks have been reduced to ALARP.
Conclusion of Intervention
Based on the evidence sampled during the inspection, ONR is of the opinion that SL has implemented adequate arrangements for compliance with LC 15.
ONR judges that an inspection rating of Green (no formal action) is appropriate for compliance against LC 15 (periodic review). ONR identified three minor shortfalls which will be followed up as three Level 4 RIs.