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 Vitrification Plant (WVP) is implementing adequately SL’s site-wide arrangements for compliance with Licence Condition 36. I selected this combination of facility and licence condition based on the high hazard posed by the Highly Active Liquor (HAL) handled within the vitrification process, and thus the importance of maintaining an effective organisation to deliver safe operations within the facility.
Licence Condition 36 (LC36) requires the licensee to provide and maintain adequate human and financial resources to ensure the safe operation of the licensed site. Additionally, the licensee should make and implement adequate arrangements to control any change to its organisational structure; such arrangements shall include the ability to classify such changes according to their safety significance.
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, that the site-wide arrangements for compliance with LC36 have been implemented adequately within the WVP facility, whilst noting that, in a couple of areas, they have exceeded the site requirement, although this was not formally documented. Given that the site is in the process of reviewing and updating those arrangements, I have identified to the licensee that this is an opportunity to provide feedback on an area of good practice to the site process owner, which it has recognised.
WVP is about to initiate a reasonably significant change to its internal organisation, driven by a decision to improve the clarity of responsibility, as well as alignment to the boundaries of their production stream. I consider that future regulatory monitoring of the effectiveness of this change, in terms of its potential impact on safety performance within the facility, is most efficiently achieved through engagement meetings over the next year.
It is my opinion that the licensee has implemented adequately the arrangements for compliance with LC36. I have therefore recorded an IIS rating of 3 (adequate) against Licence Condition 36 (Organisational capability)
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.