- Site: Sellafield
- IR number: 21-077
- Date: September 2021
- LC numbers: 35
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. One such inspection was performed to assess the Special Nuclear Materials (SNM) Value Stream’s compliance with Sellafield Ltd’s corporate arrangements for Licence Condition (LC) 35 (Decommissioning).
The purpose of this intervention was for ONR to inspect the adequacy of implementation of the licensee’s formal arrangements for compliance with Licence Condition (LC) 35 (decommissioning) by the SNM Value Stream. This inspection covered both SNM North (N) and SNM South (S). The overall adequacy of the licensee’s formal arrangements has been considered separately in another ONR intervention.
Interventions Carried Out by ONR
On 7 September the ONR Site Inspector for SNM, together with an ONR Nuclear Liabilities Specialist Inspector carried out a one-day licence condition compliance inspection of SNM. The inspection was undertaken jointly with the Environment Agency. A member of the licensee’s Nuclear Intelligence and Independent Oversight (NI&IO) team also participated. The inspection took place at the Sellafield site and comprised discussions with facility staff, and reviews of relevant documentation.
LC 35 requires the licensee to make and implement adequate arrangements for the decommissioning of any plant or process that may affect safety, and to make arrangements for the production and implementation of decommissioning programmes. The inspection focused on the requirements for transition into, and delivery of the Post Operational Clean Out (POCO) phase of decommissioning. The inspection did not consider the safety case assessments being produced to support the POCO of Finishing Lines 5 and 6 as these are subject to separate regulatory oversight by an ONR Project Inspector as part of ONR permissioning activities.
We used the following ONR technical inspection guidance for this inspection:
- NS-INSP-GD-035, Revision 6, issued in April 2019.
Explanation of Judgement if Safety System Not Judged to be Adequate
This was not a system-based inspection, and therefore no judgement has been made on the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the inspection we sampled documentary evidence relating to progress with preparation and delivery of POCO activities. The areas sampled were in accordance with the licensee’s arrangements. Some documents had not been produced at the required stage because that stage had been achieved before the corporate requirements existed. These are being produced retrospectively where a net benefit to do so remains. We consider this to be pragmatic and proportionate.
We were able to establish the linkage from the requirements set out in the licence condition through to site implementation noting where improvements have been captured through a regulatory issue elsewhere.
We did not identify any significant shortfalls in the implementation of the licensee’s formal arrangements and are satisfied that the licensee is complying with its legal duties.
Conclusion of Intervention
We judge that the licensee has adequately implemented its arrangements for compliance with LC 35 (decommissioning) based on the evidence sampled at the time of this inspection. We have assigned an inspection rating of Green (No formal action). We did not identify any matter impacting on nuclear safety that requires immediate regulatory action. We raised one Level 4 Regulatory Issue (lowest level) to support the development of an overarching SNM POCO Strategy Paper and promote its timely completion. We provided regulatory advice to consider the benefit of writing a Management of Organisational Change Paper of Principle associated with the end of Finishing Line 5 Operations.