- Site: Sellafield
- IR number: 21-015
- Date: May 2021
- LC numbers: 15, 22
Executive summary
Purpose of Intervention
In accordance with the Office for Nuclear Regulation’s (ONR’s) Sellafield Strategy, each year ONR performs a series of planned compliance inspections of selected licence conditions, targeted at those facilities with significant importance to nuclear safety. The inspection was undertaken in line with the ONR Sellafield Decommissioning, Fuel & Waste Division’s regulatory approach to the COVID-19 pandemic.
This record describes the outcome from a planned compliance inspection at the Magnox Swarf Storage Silo (MSSS) facility on the Sellafield Site. This intervention targeted MSSS as it is a high hazard facility and its continued safe operation during the COVID-19 pandemic is key for continued nuclear safety of the Sellafield site. The purpose of the inspection was to confirm Sellafield Limited’s (SL) compliance with its corporate arrangements for Licence Conditions (LC): 15 (Periodic Review); and 22 (Modification or Experiment on Existing Plant).
The inspection began with a review of evidence with the appropriate members of the Licensee organisation and then an inspection of the facility, noting the limitations in place, at the time, as a result of COVID-19. At the time of this intervention MSSS operations had returned to near pre-COVID-19 levels and the measures in place associated with the pandemic were also subject to inspection.
In response to the pandemic, SL has recognised that its existing corporate compliance arrangements should remain unchanged and continue to be complied with where possible. Nonetheless, as a contingency, SL has developed variations to some of its corporate arrangements in order to introduce some flexibility, but in a way which still maintains compliance with legal obligations. SL has a variation to its corporate arrangements associated with LC 22, however, this variation has been in place a number of years and has not been affected by the pandemic.
Interventions Carried Out by ONR
This inspection sought evidence of compliance against LCs 15 and 22 and were linked by consideration of a common theme of SL’s ability to maintain the safety case in light of the cognitive trend on safety case related incidents described in an existing Regulatory Issue.
The inspection began with the examination of evidence with representatives from the Operational and Project Safety Case Teams followed by an inspection of the facility. The inspection concluded with a de-brief with the Head of Operations for MSSS and inspection support team.
Explanation of Judgement if Safety System Not Judged to be Adequate
This section is not applicable.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
In relation to LC 15, the inspection focussed on the management of shortfalls raised since the last review of the safety case. I found that compliance with SL’s corporate arrangements was being maintained and found evidence sufficient to provide confidence that shortfalls had been managed adequately.
In relation to LC 22, the inspection focussed on examination of evidence that MSSS had managed modifications to its plant in line with its extant arrangements. I found that MSSS had implemented a Command and Control (C&C) matrix to manage modifications, this had been put in place using the SL variations process. Initially, this process had been implemented to control low risk construction activities, however evidence showed significant modifications had been carried out using the C&C instead of the SL Plant Modification Proposal (PMP). Use of the C&C is a significant departure from SL’s extant corporate arrangements for compliance with LC22. Therefore, a level 3 Regulatory Issue (seek Improvement) has been raised to track SL improvements to address the compliance gap.
In addition, I found an area for improvement in relation to management of changes to the safety case and consideration of all aspects of the case in the modification, as such I have raised a Level 4 Regulatory Issue (the lowest level) to track SL improvements to address the compliance gap.
In relation to social distancing measures, I found the measures implemented by MSSS to be robust with the arrangements developed such that operations could continue with minimal disruption.
Conclusion of Intervention
The LC 15 compliance inspection concluded that the licensee had adequately implemented its arrangements for the aforementioned Licence Condition. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited.
The LC 22 compliance inspection concluded that, whilst the licensee had adequately implemented its arrangements in respect of the PMP process, implementation of the C&C process is not considered part of SL’s compliance arrangements as it was implemented locally by the facility. In addition, it does not comply with LC 22 (4) in that it seeks to make modifications or carry out experiments on existing plant but makes no provision for the classification according to their safety significance. I therefore consider, noting the ONR guidance on inspection ratings, that an inspection rating of Amber (seek improvement) is merited here for the MSSS facility on the Sellafield Site.
In the case of LC 22, Level 3 & 4 Regulatory Issues have been agreed with SL to track SL’s progress in addressing the shortfalls relating to MSSS’s compliance with LC22 and the safety case, respectively.