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 intervention was undertaken to determine if the Waste Treatment Complex (WTC) facility is implementing adequately SL’s site-wide arrangements for compliance with Licence Conditions 11 and 12. I selected this combination of facility and licence condition to provide me with evidence of the licensee’s management of the Duly Authorised Person (DAP) role, which is central to the safe operation of that facility, and to confirm that the facility had adequate provision for responding to an event in the Operating Unit.
Licence Condition 11 (LC11) requires the licensee to make and implement adequate arrangements to ensure that they can deal with any accident or emergency arising on the site, and their effects.
Licence Condition 12 (LC12) requires the licensee to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform any duties which may affect the safety of operations on the site.
My inspection, which comprised discussions with SL staff and examination of plant documentation, was completed in accordance with the following formal ONR guidance:
Not applicable; this was not a Safety System inspection.
I judged, from the evidence examined, and from previous interactions with the licensee in this area of the site, that the site-wide arrangements for compliance with LC11 have been implemented adequately, and that relevant site-wide enhancements in emergency management capability (Emergency Management Improvement Programme) are being suitably delivered within the facility. Although there have been improvements in the implementation within the Operating Unit over this last 18 months, the programme of improvements has not yet completed delivery, and there are a number of opportunities for further improvement that have been identified.
I judged, from the evidence examined, that the site-wide arrangements for compliance with LC12 have been implemented adequately within the WTC facility; the evidence I sampled demonstrated that the facility was suitably managing its process for assessment and qualification of the DAP role in accordance with these arrangements.
It is my opinion that the licensee has adequately implemented the arrangements for compliance with LC11. The programme of training is still being developed and delivered, but I noted evidence of improvements in operational performance and it is my opinion that an IIS rating of 3 (adequate) against Licence Condition 11 (Emergency arrangements) is appropriate.
It is my opinion that the licensee has adequately implemented the arrangements for compliance with LC12. Furthermore, from the sample evidence reviewed I noted some areas of good practice and identified no major areas for improvement. Consequently, it is my opinion that an IIS rating of 2 (good) against Licence Condition 12 (Duly authorised and other suitably qualified and experienced persons) is appropriate.
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.