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Sellafield Site - Inspection ID: 50317

Executive summary

Date(s) of inspection:

September 2022

Aim of inspection

The Office for Nuclear Regulation (ONR) undertakes regulatory interactions with Sellafield Limited in accordance with a strategy defined by its Sellafield, Decommissioning, Fuel and Waste (SDFW) Division.

The SDFW Division strategy is implemented via the “ONR Sellafield Compliance, Intelligence and Enforcement Sub-Division Plan 2020 - 2025” which includes five-yearly Corporate Licence Condition Inspections (CLCIs) to examine:

  1. Whether Sellafield Limited’s site-wide / corporate written arrangements are adequate to ensure the site’s compliance with the conditions of its nuclear site licence; and,
  2. Implementation of Sellafield Limited’s arrangements at the site-wide / corporate level.

Sellafield Limited’s corporate arrangements to comply with the expectations of nuclear site Licence Condition 28 (LC28) “Examination, inspection, maintenance and testing” were last inspected by ONR in December 2015 (ONR-SEL-IR-15-076). A CLCI for LC28 was therefore overdue against the anticipated 5-year cycle, a situation primarily caused by the COVID-19 pandemic.

Sellafield Limited’s implementation of its arrangements for LC28 at facility level is inspected to a frequency that is justified in the inspection plans of relevant site inspectors in accordance with ONR’s “Guidance for Inspection Strategy Planning and Recording” (ONR-INSP-GD-059). In addition, LC28 is included within the established scope of System Based Inspections (SBIs) in accordance with Appendix 1C of ONR-INSP-GD-059.

Aside from LC28, several other pieces of legislation place legal obligations upon Sellafield Limited for the purposes of Examination, Inspection, Maintenance and Testing (EIMT) including; the Ionising Radiations Regulations 2017 (IRRs); the Nuclear Industries Security Regulations 2003 (NISR); the Control of Asbestos Regulations 2012; the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER); the Provision and Use of Work Equipment Regulations 1998 (PUWER); the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR); the Pressure Systems Safety Regulations 2000 (PSSR); and, the Construction (Design and Management) Regulations 2015 (CDM).

During this inspection ONR sought assurance on Sellafield Limited’s means of integrating the requirements from other relevant legislation with the arrangements made to comply with LC28. To this end, the inspection covered the following additional topics:

  1. Conventional health and safety;
  2. Nuclear security; and,
  3. Follow-up on prior themed inspections.

Subject(s) of inspection

  • LC 28 - Examination, inspection, maintenance and testing - Rating: GREEN

Key findings, inspector's opinions and reasons for judgement made

We considered that the engagement prior to and during the inspection allowed us to complete a meaningful CLCI of LC28. We considered that all the objectives of this inspection were met.

In relation to LC28, on the basis of the discussions during the inspection and the evidence sampled before and during this inspection we identified:

  1. Three areas of good practice relating to delivery of the overall inspection;
  2. Two areas of good practice relating to Sellafield Limited’s LC28 arrangements and/ or their implementation; and,
  3. Three items of regulatory advice relating to Sellafield Limited’s LC28 arrangements and/ or their implementation.

In relation to LC28, on the basis of the evidence sampled before and during this inspection, we identified the following regulatory findings relating to Sellafield Limited’s LC28 arrangements and/ or their implementation, representing gaps against relevant good practice:

  1. Plant which may affect safety;
  2. System Engineering resources;
  3. Application of the expectations for LC28 to packaged radioactive wastes and spent fuel;
  4. LC28 Compliance Matrix and records;
  5. Adequacy of the data in the Site Master Schedule to support the LC28 arrangements; and,
  6. LC28 Improvement Plan.

We also identified a regulatory finding which was relevant to EIMT and other obligations. This was followed up with the Sellafield Limited Management System team after the inspection and a way forward was agreed.

Full details of the areas of good practice, regulatory advice and regulatory findings are in the full Inspection Record (IR) which is shared with Sellafield Limited.

Having considered these regulatory findings I have raised five Level 4 (the lowest level) RIs:

  1. Plant which may affect safety;
  2. System Engineering resources;
  3. Packaged radioactive wastes and spent fuel;
  4. Detailed matters; and,
  5. LC28 Improvement Plan.

In relation to the additional topics covered during this inspection (conventional health and safety, nuclear security and follow-up on prior themed inspections), feedback is provided in the full IR.

The Sellafield Limited personnel present at the hot debrief were in broad agreement with the outcomes of this inspection.

Conclusion

Five Level 4 (the lowest level) Regulatory Issues have been raised to monitor Sellafield Limited’s progress to address the six regulatory findings relating to Sellafield Limited’s LC28 arrangements and/or their implementation identified during this inspection. These are:

  1. Plant which may affect safety;
  2. System Engineering resources;
  3. Packaged radioactive wastes and spent fuel;
  4. Detailed matters; and,
  5. LC28 Improvement Plan.

I considered that an Inspection Rating of Green (No Formal Action) for LC28 was appropriate since no significant shortfalls against relevant good practice have been identified.