- Site: Sellafield
- IR number: 21-119
- Date: November 2021
- LC numbers: 7, 15, 25
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Ltd) against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. The planned inspection schedule for 2021/22 identifies the Licence Conditions (LCs) that will be inspected during this period. The LC 15 inspection is covered by Decision Record DR21/006.
The purpose of this intervention was for ONR to (1) Engage on the Sellafield Ltd Periodic Safety Review for the Advanced Gas Reactor Storage Pond (AGRSP) for the Mechanical Engineering, Nuclear Liabilities Regulation and Leadership for Management and Safety Specialisms, as part of ONR’s programme of Licence Condition (LC) 15 (Periodic review) assurance; (2) determine the adequacy of implementation of Sellafield Ltd’s arrangements for compliance with LC 7 (Incidents on the site) and LC 25 (Operational records) at the Fuel Storage (formerly the Oxide Fuel storage Group (OFSG)) facilities .
The overall adequacy of Sellafield Ltd's site-wide arrangements for LC 15, LC 7 and LC 25 is considered separately in other ONR interventions
Interventions Carried Out by ONR
I, the Site Inspector, for Fuel Storage undertook interventions for LC 15, LC 7 and LC 25, these included:
- LC 15 Mechanical Engineering input into the AGRSP PSR;
- LC 15 Nuclear Liabilities Regulation Input into the AGRSP PSR;
- LC 15 Human Factors Safety Input into the AGRSP PSR;
- LC 7 notification, recording, investigation and reporting of incidents on the site;
- LC 25 records for operational log keeping, compliance with operating rules and plant parameters, accumulation and storage of radioactive waste and spent fuel.
Explanation of Judgement if Safety System Not Judged to be Adequate
Not applicable since these were not safety system-based inspections.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the LC 15 initial engagement, we discussed with Sellafield Ltd key focus areas relevant to periodic safety review. The specialist inspectors had the opportunity to ask questions and gain an understanding of key hazards and control measures applied. A facility plant visit allowed us to observe the structures, systems and components important to safety and to understand their condition. This engagement is not rated but will inform future regulatory engagements for the AGRSP PSR.
For LC 7, Fuel Storage demonstrated that it has a good reporting culture, it understands and has implemented the Sellafield Ltd arrangements for managing events as part of the wider Spent Fuel Services (SFS) operating unit, supplemented by local arrangements and is managing actions. Statutory reporting requirements are being met.
One area for improvement in relation to providing adequate justification for not undertaking an investigation had been identified by Fuel Storage as part of its own assurance arrangements, and Fuel Storage has taken action to address this. Consequently, I do not intend to take any regulatory action, but will monitor this as part of routine regulatory engagement.
For LC 25, I was satisfied that Fuel Storage is compliant with the Sellafield Ltd arrangements for LC 25 for the areas sampled. I found evidence that Fuel Storage has a records retention schedule broadly aligned to the site’s requirements. Electronic records were sampled on the day and found to be retrievable, and a paper signed copy of a shift log was subsequently sampled having been retrieved from storage. Records from fuel stored in B560 aligned with those held by ONR Safeguards. Fuel Storage is also implementing a records improvement programme which I am of the opinion will further enhance its records management capabilities.
I was unable to test the waste management records due an unplanned unavailability on the day and I noted potential shortfalls in the corporate records arrangements in this area. These have been passed to the Corporate Inspector for consideration. I plan to return to cover this element of LC 25.
Our findings were shared with, acknowledged and accepted by Fuel Storage’s management as part of normal intervention feedback.
Conclusion of Intervention
On the basis of the evidence sampled at the time of the inspection, I judge that Fuel Storage has adequately implemented Sellafield Ltd’s arrangements for LC 7 and LC 25, noting some minor shortfalls were identified. Noting the ONR guidance on inspection ratings, it is my opinion that inspection ratings of Green (no formal action) are merited. LC 15 was an unrated intervention and has informed future engagement for the AGRSP PSR.