The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, defines the Licence Conditions (LC) that will be inspected over this period.
This planned inspection was undertaken to determine if the Decommissioning Directorate is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 7 (Incidents on site).
Licence Condition 7 (LC7) requires the licensee to make and implement adequate arrangements for the notification, recording, investigation and reporting of incidents occurring on the site.
My inspection, which comprised discussions with SL staff and examination of site documentation, focussed on the following areas:
In preparing and conducting my inspection I used ONR inspection guide NS- INSP-GD-007 Revision 2 and was accompanied by a specialist LfE (Learning from Experience) inspector.
Not applicable; this was not a Safety System inspection.
I judge, from the evidence presented that SL’s site-wide arrangements for compliance with LC7 have been appropriately implemented. However, I identified some specific procedural weaknesses and examples of failures to follow procedures. SL has, independent of the inspection, recognised through its own audit of its arrangements that these problems exist and has self-assessed its arrangements as “below standard”. A phased programme of improvements has been identified in regard to the efficiency of the Performance Improvement (PI) function, including increasing the visibility of tangible improvements that SL’s LC7 arrangements are intended to deliver.
The programme appears comprehensive and when fully implemented will address many of the issues identified in this inspection. However, there appears to be no overall project plan, i.e. timescales for delivery of each of the programme elements. SL nevertheless considers the programme needs to be implemented as soon as possible.
My review of the corrective actions for SR&DP (Sellafield Remediation and Decommissioning Projects, a part of Decommissioning Directorate) revealed a significant number of overdue issues. From the evidence provided it would appear that there has been insufficient management commitment to addressing these actions.
I also identified a number of minor shortfalls in the licensee’s control of delivery timescales for the completion both of investigations and subsequent corrective actions.
Having reviewed these shortfalls, I am content that none present any immediate safety concern.
The licensee has extensive and complex arrangements which fundamentally meet the requirements of LC7; however their complexity has led to inconsistencies between its procedures and errors in their implementation. Although SL has self-identified many of these shortfalls and already has a programme to improve its arrangements, based on the evidence from my inspection, I have awarded an IIS rating 4 (below standard) against Licence Condition 7 (Incidents on the site).
My observations were shared with, and accepted by the licensee as part of normal inspection feedback. One ONR Regulatory Issue was raised as a result of this inspection.