Executive summary
Date(s) of inspection: July 2024
Aim of inspection
The purpose of this inspection was to seek assurance that Sellafield Limited’s arrangements for compliance with Licence Condition 23, 24, 35 & 36 are adequately implemented at Magnox Remediation (MR) and comply with the relevant expectations of ONR.
This Inspection was in connection with the recent move of MR into the Post Operational Clean Out (POCO) phase and was a joint ONR and Environment Agency Inspection.
Subject(s) of inspection
- LC23 - Operating rules - Rating: Green
- LC24 - Operating instructions - Rating: Green
- LC35 - Decommissioning - Rating: Green
- LC36 - Organisational capability - Rating: Green
Key findings, inspector's opinions and reasons for judgement made
In relation to LC23 (Operating rules) and LC24 (Operating instructions), the inspection targeted the changes to the safety case in Magnox Remediation (RM) during the transition to POCO. Through sampling of documentation and discussion with personnel, Sellafield Ltd provided evidence of the following:
- The safety case has been maintained proactively, following a documented safety case strategy to progressively suspend parts of the safety case in line with a reduction in hazards following plant run downs.
- Changes to the safety case were approved under Sellafield Ltd’s LC22 compliance arrangements.
- Clearance certificates and operator instructions have been updated in a timely manner to reflect changes to the safety case, with Safety Case Implementation Plans used to identify and track the completion of implementation actions.
Operators have received suitable briefing to inform them about the changes to the safety case.
Based on the areas sampled, I did not identify any shortfalls with respect to LC23 or 24. I considered the strategy followed to maintain the safety case up-to-date through the transition to POCO to be an example of good practice.
In relation to LC35, I sampled evidence associated with the licensee’s compliance with its formal arrangements for the preparation and delivery of POCO within MR. In particular, I reviewed the arrangements for carrying out POCO readiness reviews, end state documentation, retention of knowledge, POCO delivery and governance arrangements.
Overall, based on the evidence sampled, I was satisfied that the MR is following the Sellafield Ltd corporate arrangements for transition to POCO and have adequate governance arrangements in place.
In relation to LC36, I undertook a review of the Management of Change processes being implemented for the changes in the MR personnel structure as it transitions to POCO and the changes to the Minimum Safe Manning Levels.
Overall, based on the evidence seen, I am content that MR have adequately implemented the Sellafield Ltd LC36 arrangements for management of change.
From the areas sampled, I provided some regulatory advice but did not identify any significant shortfalls in the implementation of the licensee’s arrangements which would necessitate a further inspection of those arrangements earlier than currently planned.
This was a joint ONR and Environment Agency inspection, during the inspection the Environment Agency undertook a review of the POCO arrangements in place for the environmental case, expected discharges, sampling arrangements and POCO waste streams. Overall, the Environment Agency was content with the arrangements in place for POCO at MR and will capture their findings in an Environment Agency Radioactive Substances Compliance Assessment Report (RASCAR).
Conclusion
On the basis of the evidence sampled at the time of the inspection, I judge that Sellafield Limited has adequately implemented its arrangements for LC 23, 24, 35 & 36 in Magnox Remediation and an inspection rating of Green (no formal action required) is appropriate.