The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) against a strategy defined by the ONR Sellafield Programme. My planned inspection schedule PP5 for the current regulatory year (covering April 2015 – March 2016), the content of which is guided by that strategy, identifies the Licence Conditions (LCs) that will be inspected over this period.
I undertook the planned LC 7 inspection by meeting with facility representatives in both areas of the Effluent & Encapsulation Plants (E&EP) Operating Unit, Low Active Effluent Management Group (LAEMG) and Encapsulation Plants. This OU was selected for inspection since it consists of a number of ageing facilities with a wide range of nuclear safety challenges and the possibility of the extension of operating life to provide waste management services or other areas of the site. All of which requires E&EP to learn from Operational Experience (OE) both from incidents and events on the site, as well as from other relevant external sources to maintain the focus on nuclear safety whilst it pursues new opportunities in waste management in the interests of high hazard reduction both on the Sellafield Site as well as the UK.
The purpose of Licence Condition 7 (LC7) is to ensure that incidents on the site are notified, recorded, investigated and reported by the Licensee.
In light of the recent LC7 Inspections, particularly in MAGNOX and Sellafield Corporate, I chose not to examine the implementation of those aspects of SL’s LC 7 arrangements in my inspection but to inspect the adequacy with which the learning from these earlier LC7 inspections had been disseminated through the site process and the local E&EP process. I reviewed what learning has been embedded into the site, local LAEMG/Encapsulation Plants and Self-Assessment processes and the resultant changes. The target of my inspection was as follows:
Not applicable; this was not a Safety System inspection.
I consider that SL’s arrangements for compliance with LC 7 have been effectively implemented within Effluent and Encapsulation Plants.
I noted several areas of good practice and identified some improvements that could be made, all of which were accepted by the licensee. I do not specifically intend following up the identified areas for improvement, but they will inform my future regulatory engagement as appropriate.
I consider the facility’s implementation of the site’s arrangements for LC7 is good in many areas. For instance, there was evidence of the number of overdue actions and investigations being reduced and the management of these actions was robust. However, there was no evidence that the licensee neither exceeds the requirements nor actively peruses the potential for improvement. For these reasons, on balance, I consider the inspection findings merit an IIS rating of 3 (Adequate), against LC7. This is consistent with the IIS ratings guidance, for which the relevant extract is:
“…Arrangements meet guidance requirements. Some opportunities for improvement under ALARP. Areas for improvement known, but being addressed only slowly. Site inspector able to identify minor points for improvement.”
My findings were shared with, and accepted by, the dutyholders as part of normal inspection feedback. No ONR Regulatory Issues were raised as a result of this inspection.