Date(s) of inspection:
- February 2023
Aim of inspection
The Office for Nuclear Regulation (ONR) undertakes all its regulatory interactions with the Sellafield site licensee, Sellafield Ltd., against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste (SDFW) Division. In accordance with this strategy, this was a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 5 (LC5) “Consignment of nuclear matter”.
The principal purpose of this CLCI was to seek assurance: that Sellafield Ltd.’s site-wide / corporate written procedures are adequate to ensure the Sellafield site’s compliance with LC5; and, that the LC5 procedures are being adequately implemented at the site-wide / corporate level.
Subject(s) of inspection
- LC 05 – Consignment of nuclear matter – rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The Office for Nuclear Regulation (ONR) undertook a planned Corporate Licence Condition Inspection (CLCI) of Licence Condition 5 (LC5) “Consignment of nuclear matter” at Sellafield site through inspection of the Sellafield Ltd. Office of the Consigning Authority (OCA), a sub-team within the Infrastructure Consignment and Operational Services Team. The inspection focused on the Relevant Good Practice (RGP) relevant to ONRs nuclear safety purpose, as captured within NS-INSP-GD-005 (Revision 5.1) and the adequacy of Sellafield Ltd.’s procedures to maintain compliance. However, the inspection also included the interfaces relevant to ONR’s nuclear security and nuclear safeguards purposes for the consignment (transport) of nuclear matter / Qualifying Nuclear Material (QNM).
It was found that the OCA has been subject to a recent Sellafield Ltd. independent internal assurance review on the topic of consignments (completed in 2022) which was directly relevant to LC5 and this inspection. This inspection identified a broad range of shortfalls within the LC5 procedures, records, training and governance, which were consistent with the shortfalls identified during the Sellafield Ltd. independent internal assurance review. This inspection saw evidence that actions to address the assurance review shortfalls were captured in the Sellafield Ltd. action tracking system (ATLAS), and that the OCA had commenced work to address these. No significant shortfalls were identified which were considered to impact upon the delivery of safety functions on the site. The inspection recognised the improvements being driven by the Sellafield Ltd internal assurance review, and therefore, to avoid imposing unnecessary regulatory burden which would look to achieve the same outcome as the ongoing work, it was considered proportionate to raise a Level 4 (the lowest level) Regulatory Issue to monitor delivery of the actions arising from the Sellafield Ltd. independent internal assurance review until the final action is addressed (circa 12 months).
After considering the evidence within the updated procedures for compliance with LC5, specifically around Sellafield Ltd.’s process for seeking Consent from ONR under LC5(1), minor shortfalls were raised which have been captured in a second Level 4 Regulatory Issue.
Evidence was provided that Sellafield Ltd. is adequately considering the nuclear security and nuclear safeguards requirements for the consignment (transport) of nuclear matter / Qualifying Nuclear Material.
Notwithstanding the two Level 4 Regulatory Issues raised to monitor Sellafield Ltd. improvements to its LC5 procedures, overall, on the basis of the evidence sampled, I considered that an inspection rating of Green (No Formal Action) for the Sellafield Ltd. Corporate Licence Condition Inspection of LC5 (Consignment of Nuclear Matter) was appropriate.
On the basis of the evidence sampled related to ONR’s nuclear safety purposes, it was considered that an inspection rating of Green (No Formal Action) for the Sellafield Ltd. Corporate Licence Condition Inspection of LC5 (Consignment of Nuclear Matter) was appropriate.
On the basis of the evidence sampled related to ONR’s nuclear security and nuclear safeguards purposes, no regulatory findings were identified.
In relation to ONR’s transport purposes, relevant evidence sampled will be shared with ONR’s transport inspector to inform an upcoming Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 inspection.
Two Level 4 (the lowest level) Regulatory Issues have been raised to monitor Sellafield Ltd.’s progress to address the two regulatory findings relating to Sellafield Ltd.’s improvements to the LC5 procedures identified during this inspection.