Date(s) of inspection:
- December 2022
Aim of inspection
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 Corporate Licence Condition Inspection (CLCI), targeted at Sellafield Limited’s site wide corporate arrangements for compliance with Licence Condition 15 (LC15) “Periodic review” and their implementation, was undertaken between 7 and 9 December 2022.
Subject(s) of inspection
- LC15 – Periodic Review – Rating: Amber
Key findings, inspector’s opinions and reasons for judgement made
ONR completed a Corporate Licence Condition Inspection (CLCI) of Licence Condition 15 (LC15) “Periodic review” during 7-9 December 2022. It was undertaken by the ONR Corporate Inspector for SDFW, the ONR SDFW Inspector leading Periodic Safety Review (PSR) and several other SDFW inspectors.
This inspection consisted of discussions with Sellafield Limited staff and a review of records, documents and processes specific to LC15.
I sampled the training records for several personnel with responsibilities under LC15 and confirmed that relevant training was complete and in-date.
From my review of the sample of records and discussions with Sellafield Limited personnel, I saw evidence that Sellafield Limited was generally maintaining corporate level arrangements for PSRs consistent with Relevant Good Practice (RGP). The corporate arrangements for LC15 clearly outlined the expectations for PSRs across the Enterprise. In my opinion, the Sellafield Limited personnel that were interviewed had extensive knowledge and experience. I commended the licensee for recognising the need to update its LC15 arrangements and the preparations to do so.
However, I noted two significant compliance gaps in Sellafield Limited’s LC15 corporate arrangements which are as follows.
The first significant gap in the LC15 arrangements was that the corporate arrangements do not ensure that a full list of current RGP, against which the review will be carried out, is available as input to PSRs. The second significant gap is that the arrangements do not ensure that positive findings from a PSR will be captured, and although negative PSR findings require capturing, the corporate LC15 arrangements do not ensure that these negative PSR findings are systematically categorised by their nuclear safety significance and readily available at an Enterprise level or Value Stream level.
I found these gaps to be significant because: the first gap allows for the potential to allow a PSR to be performed without measuring the facility in question against modern standards which is a fundamental purpose of a PSR; and, the second gap allows for a PSR to be performed but significant learning may not be extracted from the results and the Enterprise may not be able to understand the areas of highest or uncontrolled risk in the facility.
Thus, based on the evidence seen during the inspection, specifically the significant shortfalls identified above, I have rated this inspection Amber(Seek Improvement). Following application of ONR’s Enforcement Management Model, I have raised a Level 3 Regulatory Issue and provided Regulatory Advice to address the compliance gaps; this level of enforcement has been informed by dutyholder’s positive response in accepting the inspection findings and putting in place plans to address the identified shortfalls.
During the inspection, I also identified minor compliance shortfalls which will be tracked by means of a Level 4 (lowest level) Regulatory Issue.
Based on the evidence seen during the inspection, I have rated this inspection Amber(Seek Improvement). I have raised a Level 3 Regulatory Issue and provided Regulatory Advice to address the compliance gaps; this level of enforcement has been informed by dutyholder’s positive response in accepting the inspection findings and putting in place plans to address the identified shortfalls. Other minor compliance shortfalls are being tracked by means of a Level 4 Regulatory Issue.