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Sellafield - LC21 arrangements inspection

  • Site: Sellafield
  • IR number: 21-092
  • Date: September 2021
  • LC numbers: 21

Executive summary

Purpose of Intervention

The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Limited, against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.  In accordance with this strategy, a planned inspection of Sellafield Limited’s corporate site-wide arrangements for compliance with Licence Condition 21 (LC21) “Commissioning” was carried out on 21-23 September 2021.

The objective of the inspection was to gain assurance, judged against ONR’s expectations, in respect of:

  • Sellafield Limited’s site-wide corporate arrangements made to comply with LC21;
  • The interfaces between Sellafield Limited’s site-wide corporate arrangements made to comply with LC21 and Sellafield Limited’s arrangements made to comply with other relevant Licence Conditions (LCs);
  • The interfaces between Sellafield Limited’s site-wide corporate arrangements made to comply with LC21 and Sellafield Limited’s arrangements made to comply with other legal duties for which ONR is the enforcing authority;
  • Experience and training of selected persons assigned responsibility under Sellafield Limited’s site-wide corporate arrangements to address the requirements of LC21;
  • Records [Licence Condition 6 (LC6) “Documents, records, authorities and certificates” refers] made to demonstrate compliance with LC21;
  • Sellafield Limited’s means of gaining internal assurance of compliance with LC21; and,
  • Sellafield Limited’s learning from incidents related to commissioning.

Although this inspection focussed on Sellafield Limited’s LC21 arrangements it covered some aspects of implementation of these arrangements too. In particular, we sampled: application of the arrangements to two commissioning projects; the experience and training of selected persons appointed to commissioning roles; how Sellafield Limited gains assurance relating to its LC21 arrangements; and, Sellafield Limited’s learning from incidents related to commissioning.

Interventions Carried Out by ONR

The inspection was carried out by the Sellafield Compliance, Intelligence and Enforcement (SCIE) Corporate Arrangements Inspector with support from: a Control & Instrumentation (C&I) Specialist Inspector; a Civil Nuclear Security & Safeguards (CNS&S) Inspector; a C&I Nuclear Associate; and, a Human Factors Specialist Inspector.

The inspection comprised discussions with Sellafield Limited staff and reviews of a targeted sample of Sellafield Limited’s documentation. The scope and priorities of the inspection took into account intelligence gained from other ONR interventions.

ONR expectations relevant to the inspection included:

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

I (SCIE Corporate Arrangements Inspector) consider that the engagement prior to and during the inspection has allowed a meaningful inspection of Sellafield Limited’s arrangements for compliance with LC21, which met all the inspection objectives.

On the basis of the evidence sampled before and during this inspection, I identified the following areas of good practice in respect of Sellafield Limited’s arrangements for compliance with LC21:

  • The Sellafield Limited Management System Topic Area 1.04 “Commissioning and pre-operations” arrangements have been restructured to make them easier to use and applicable to all commissioning activities.
  • Learning from experience has been used to influence the improvements already made.
  • The human factors specialism is actively considered and engaged during the commissioning process.

I identified the following areas of good practice relating to delivery of this inspection:

  • Thorough preparation for this inspection and the timely response to ONR information requests during the inspection itself.

On the basis of the evidence sampled before and during this inspection, I identified the following items of regulatory advice, summarised as follows:

  • Sellafield Limited to review whether the nuclear safeguards requirements referred to in NS-INSP-GD-021 are included within its LC21 arrangements and include them if they are not.
  • Sellafield Limited to consider better integrating supervision within its LC21 arrangements.
  • Sellafield Limited to consider including definitions of additional commissioning specific expressions within its LC21 arrangements and ensuring that such expressions are used consistently throughout.
  • For the relatively new “Start-up Manager” role and the existing Commissioning Manager and Commissioning Engineer roles, Sellafield Limited to fully include these roles within its Licence Condition 10 (LC10) “Training”, Licence Condition 12 (LC12) “Duly authorised and other suitably qualified and experienced persons” and LC21 arrangements.
  • Sellafield Limited to consider observation of Commissioning Safety Committees and other relevant committees as part of its process performance assurance activities.

On the basis of the evidence sampled before and during this inspection, I identified the following regulatory findings, summarised as follows:

  • Sellafield Limited to fully define the governance route for all commissioning documents in a manner which reflects the expectations of a graded approach.
  • Sellafield to review the interfaces between its “commissioning and pre-operations”, “design and engineering” and “safety cases” management system processes and identify and implement any changes identified which would improve the completeness and accuracy of commissioning documents.
  • Sellafield Limited to update its LC21 Compliance Matrix to appropriately reference:
    • Sellafield Limited Manual 1.04.01 “Commissioning, Pre-Operations and Start-Up Manual”; and,
    • Sellafield Limited Practice 4.07.06 “How do I Manage Office for Nuclear Regulation (ONR) Permissions?”

I consider that these findings represent relatively minor deficiencies in Sellafield Limited’s LC21 compliance arrangements when taken individually or as a whole.

I have raised three Level 4 (the lowest level) Regulatory Issues to monitor Sellafield Limited’s progress to address the shortfalls identified during this inspection.

Conclusion of Intervention

Taking the above into account, I considered that an inspection rating of Green (No Formal Action) was merited, having noted the guidance in ONR documentation.