- Site: Sellafield
- IR number: 20-019
- Date: July 2020
- LC numbers: 10, 11, 12
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited (SL)) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2020/21, updated as a result of the COVID-19 Pandemic, identifies the Licence Conditions (LCs) that will be inspected during this period.
The purpose of this inspection was for ONR to determine the adequacy of implementation of SL’s arrangements for compliance with Licence Condition (LC) 10 (Training), LC 11 (Emergency arrangements), and LC 12 (Duly authorised and other suitably qualified and experienced persons) at Mixed Oxide Demonstration Facility (MDF).
Interventions Carried Out by ONR
This compliance inspection was carried out against LCs 10, 11 and 12. It sought to seek evidence of compliance in each case.
The inspection began with a questions and answers teleconference between the inspection team, representatives from MDF and the SL Nuclear Intelligence & Independent Oversight (NI&IO). This session was supported by evidence that had been requested in advance. Further evidence was requested and provided following this session. The inspection concluded with a site inspection by the Remediation value stream site inspector, and a follow-up teleconference involving the inspection team. Regulatory judgements have been made based on the verbal answers, the observations made on the site visit and the sampling of information contained within electronic databases as well as other relevant documentation.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since this was not a safety system based inspection.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
No significant matters were identified as requiring immediate regulatory attention in relation to the implementation of the SL’s corporate arrangements for LC 10, 11 and 12 at MDF.
The inspection concluded the following:
- MDF personnel have been trained in line with the arrangements for LC 10 and those undertaking control and supervision activities have been appropriately competency assessed and appointed in line with the arrangements for LC 12. One minor shortfall was identified in relation to the documented Control and Supervision Organisation Baseline; and
- Evidence was obtained that MDF has in place an emergency response structure for normal and silent hours and has carried out emergency drills and exercises for all relevant emergency instructions, recognising the COVID-19 pandemic impact. One minor shortfall was identified in relation to the derivation of the Remediation Emergency Exercise Annual Report and Emergency Exercise Schedule.
The two minor shortfalls will be followed up as Level 4 (i.e. lowest level) Regulatory Issues (RIs) as part of routine regulatory business.
The inspection team provided regulatory advice to MDF in relation to the following:
- Improve the document control regarding Duly Authorised Person (DAP) appointment and DAP assessment; and
- Maintain full and accurate Management Safety Committee (MSC) records to include the approved minutes of meetings, in particular the use of e-mails in lieu of wet signatures.
ONR’s findings were shared with, and acknowledged by, MDF’s management as part of normal inspection feedback.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection in relation to LCs 10, 11 and 12, the inspection team judged that the MDF has adequately implemented its arrangements for compliance with Licence Conditions 10, 11 and 12 and has assigned an inspection rating of GREEN (no formal action required). Two Level 4 (i.e. lowest level) Regulatory Issues have been raised to manage the implementation of the identified areas for improvement.