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Compliance inspection of Licence Conditions 7 and 26

  • Site: Sellafield
  • IR number: 21-039
  • Date: June 2021
  • LC numbers: 7, 26

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 across Legacy Ponds but specifically targeted at the First Generation Magnox Storage Pond (FGMSP) complex on the Sellafield Site. This intervention targeted FGMSP 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): 7 (Incidents on the site); and 26 (Control and supervision of operations).

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 FGMSP 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.

Interventions Carried Out by ONR

This inspection sought evidence of compliance against LCs 7 and 26 and were linked by consideration of a common theme of SL’s ability to safely carry out lifting operations in light of the cognitive trend on incidents related to lifting operations described in an existing Regulatory Issue.

The inspection began with the examination of evidence with representatives from the FGMSP & Pile Fuel Storage Pond (PFSP) Teams followed by an inspection of the facility. The inspection concluded with a de-brief with the Senior Operations Manager for Legacy Ponds 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 7, based on a review, with the Licensee, of the process by which incidents are managed and a number of incident records, I found that compliance with SL’s corporate arrangements was being maintained and found evidence sufficient to provide confidence that incidents had been managed adequately.

In relation to LC 26, through a targeted discussion which was supported by a plant visit of FGMSP, the Licensee was able to clearly demonstrate the control and supervision in place for lifting operations. Therefore, I found that compliance with SL’s corporate arrangements was being maintained and found evidence sufficient to provide confidence that lifting operations in FGMSP were being controlled and supervised adequately.

In addition, I found areas for improvement in relation to control and supervision of lifting operations (LC 26), as such I have updated the extant 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 FGMSP to be robust with the arrangements developed such that operations could continue with minimal disruption.

Conclusion of Intervention

I consider in respect of LC7, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited.

I consider in respect of LC26, noting the ONR guidance on inspection ratings, that an inspection rating of Green (no formal action required) is merited.