Date(s) of inspection:
- March 2023
Aim of inspection
The aim of the inspection is to sample evidence of implementation of the Sellafield Limited arrangements for compliance with Licence Condition 15, specifically within the Emergency Management Capability Case, in order to inform a regulatory judgement regarding the licensee’s compliance with legal duties under the nuclear site licence.
Subject(s) of inspection
- LC 15 – Periodic Review – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
The Office for Nuclear Regulation undertakes all regulatory interactions with the Sellafield Site Licensee against a strategy defined by the ONR Sellafield, Decommissioning, Fuel and Waste Division. The strategy requires inspections to be performed against Licence Condition 15 (LC15) “Periodic Review”, which requires the licensee to make and implement adequate arrangements for the periodic and systematic review and reassessment of safety cases. The inspection was carried out against Relevant Regulatory Guidance, including:
- Nuclear Safety Technical Inspection Guide – LC15 Periodic Review, NS-INSP-GD-015 Revision 5
- Nuclear Safety Technical Assessment Guide – Periodic Safety Review (PSR), NS-TAST-GD-050 Revision 8
- IAEA Specific Safety Guide – Periodic Safety Review for Nuclear Power Plants, SSG-25
The purpose of this inspection was for ONR to assess the adequacy of the Emergency Services and Communications Safety Case (ESC SC) Case Periodic Safety Review (PSR) by ensuring that Sellafield Limited: has implemented its LC15 arrangements; and, is taking the necessary steps to continue to operate and maintain the plant in a manner that will ensure that risks will continue to be reduced so far as is reasonably practicable. The inspection was carried out in accordance with a plan shared with Sellafield Limited.
The objectives of this inspection were to; gain confidence that Sellafield Limited has undertaken an adequate PSR, accounting for lessons learnt and future foreseeable challenges; and, establish if Sellafield Limited has credible resolution plans to implement improvements identified by the PSR.
On 7 March 2023, ONR carried out an inspection of LC15 compliance relating to the ESC SC PSR. The ONR inspection team was led by the PSR project Inspector, with support from the relevant Site Inspector. The inspection involved the following activities: sampling the implementation of Sellafield Limited’s LC15 arrangements; sampling the documents produced by implementing these arrangements; and, holding relevant discussions with appropriate members of Sellafield Limited staff.
Based on the evidence obtained during these activities, ONR considers that Sellafield Limited has implemented its LC15 arrangements and produced an adequate PSR of the ESC SC. ONR also considers that the PSR accounts for lessons learned and foreseeable future challenges and that arrangements to address the actions identified during the PSR are adequate.
Since ONR considers that Sellafield Limited has adequately implemented its arrangements for compliance with LC15, ONR judges that an inspection rating of Green (no formal action) is appropriate for compliance against LC15 (Periodic Review).
It was noted that there is a forward programme of the activities to improve Sellafield Limited’s emergency response, including establishing the Emergency Management Capability Case (EMCC) which resolves issues identified in the ESC SC. A Level 4 Regulatory Issue (lowest level) will be raised to monitor delivery of the EMCC and further Items for Further Consideration and recommendations identified during the PSR process.
On the basis of the evidence sampled at the time of the inspection, ONR judged that Sellafield Limited has adequately implemented its arrangements for LC 15 in the preparation of the Emergency Services and Communications Safety Case PSR. Noting the ONR guidance on inspection ratings, it is my opinion that an inspection rating of Green (no formal action) is appropriate.
A Level 4 Regulatory Issue (lowest level) will be raised to monitor delivery of the EMCC and further Items for Further Consideration and recommendations identified during the PSR process.