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, identifies the Licence Conditions (LC) that will be inspected over this period.
This intervention was undertaken to determine if the Thermal Oxide Reprocessing Plant (THORP) area is adequately implementing SL’s site-wide arrangements for compliance with Licence Condition 7 (Incidents on the 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.
I was accompanied on my inspection by another member of ONR’s Sellafield site inspection team. My inspection, which comprised discussions with SL staff and examination of plant documentation, focussed on the following areas:
Not applicable: this was not a Safety System Inspection.
I judge, from the evidence presented, that SL’s side-wide arrangements for compliance with LC7 have been implemented appropriately at the THORP facility. I noted good practices in the use of the Apparent Cause Investigation process, the reviews of investigation reports made by the Convening Authority, the Operational Experience (OPEX) processes, and the project to implement a Trend and Self-Assessment process.
I nevertheless identified a small number of areas for improvement. These concerned challenging operators to report events and taking the operator feedback into account when identifying corrective actions at the end of the investigations. I am content that none of these present any safety concern.
I also advised on the necessity for SL to ensure THORP maintains its positive reporting culture given the changes that will be brought about by the forthcoming cessation of fuel reprocessing at the plant. This is a matter already identified by the licensee.
The licensee has adequately implemented its arrangements for compliance with LC7 at THORP. Though I noted areas of good practice, there were also a number of improvements that can be made. As such I have recorded an IIS rating of 3 (adequate) against this Licence Condition.
My observations were shared with, and accepted by the licensee as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.