- Site: Sellafield
- IR number: 21-189
- Date: March 2022
- LC numbers: 22
Executive summary
Purpose of Intervention
The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with the Sellafield site licensee (Sellafield Limited) against a strategy defined by the ONR Sellafield Subdivision. In accordance with this strategy, a planned Licence Condition (LC) compliance inspection was carried out at Alpha Operating Unit within the Remediation Value Stream.
The purpose of this inspection was to confirm that Sellafield Limited is adequately implementing its arrangements for LC 22 (Modifications or experiment on existing plant) at Alpha Operating Unit.
Interventions Carried Out by ONR
The inspection was a planned LC 22 intervention conducted at Alpha Operating Unit and was undertaken on 16 March 2022 by the ONR Site Inspector for Remediation Value Stream. The inspection comprised discussions with Sellafield Limited personnel and a review of a targeted sample of Sellafield Limited documentation. A representative of Sellafield Limited Nuclear Intelligence and Independent Oversight (NI&IO) function also participated.
LC22 (1) requires the licensee to make and implement adequate arrangements to control any modification or experiment carried out on any part of the existing plant or processes which may affect safety.
LC22 (4) also requires the arrangements to provide for the classification of modifications or experiments according to their safety significance. The arrangements shall include a requirement for the provision of adequate documentation to justify the safety of the proposed modification or experiment.
As part of the preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
- NS-INSP-GD-022 Revision 7 - LC 22 Modification Or Experiment On Existing Plant.
- ONR-INSP-GD-059 Revision 8 Guidance for Inspection Strategy Planning and Recording.
The scope and focus of the inspection took into account intelligence gained from various ONR interventions.
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 of the adequacy of implementation of any part of the safety case.
Key Findings, Inspector's Opinions and Reasons for Judgements Made
During the LC 22 inspection, I sampled evidence associated with Sellafield’s Limited compliance with its corporate arrangements for the control of modification to existing plant. From the sample inspected, I found the following:
- Sellafield Limited has suitable and sufficient processes in place to monitor the Plant Modification Proposals (PMPs).
- The control of live and overdue PMPs was effective and that Sellafield Limited was continuing to reduce the number of overdue modifications.
- The categorisation, implementation and closure of PMPs is in line with their corporate arrangements.
- Sellafield Limited proactively identified that the processes for review, oversight, audit and extension of Temporary Plant Interventions (TPI) were not aligned with the corporate arrangements. I was assured that improvement measures have already put in place to address this and to avoid re-occurrence.
- The training records for several personnel were completed and in date.
Conclusion of Intervention
Taking the above findings into account, and noting the ONR guidance on inspection ratings, I judge that Sellafield Limited has adequately implemented its arrangements for compliance with LC 22 (Modifications or experiment on existing plant) at Alpha Operating Unit. I therefore consider that an inspection rating of Green (No Formal Action) is merited.