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. As part of this Strategy ONR carries out Licence Compliance Arrangements Inspections. These examine whether SL’s site-wide arrangements are adequate to ensure the site’s compliance with the conditions of its nuclear site licence
This planned intervention was undertaken over 19-22 October 2015 to examine the adequacy of the site’s quality management system in respect of matters which may affect safety. This management system is important both to compliance with the law, as it should give structure, discipline and transparency to all of the site’s arrangements for complying with the Nuclear Site Licence, and to the efficiency and effectiveness with which the site manages risk reduction of its nuclear legacy. Both of these aspects were considered.
Whilst there has been no ONR inspection of the general arrangements made under LC17 at Sellafield for some years, evidence from other inspections over recent years though has raised some concern regarding how arrangements within the management system are developed and their implementation planned. Consequently, this area was selected as the main focus of my inspection. I was also aware from previous meetings that Sellafield Limited is dissatisfied with aspects of its management system and has plans to improve it. The inspection, therefore, had the secondary aim of providing evidence and feedback to Sellafield Ltd. to assist the successful development of their improvement plan.
Licence Condition 17 (LC17) requires that the licensee shall: “establish and implement management systems which give due priority to safety.” [and]: “ within its management systems, make and implement adequate quality management arrangements in respect of all matters which may affect safety.”
My inspection comprised discussions with SL staff and examination of documentation. It focussed on the arrangements for the preparation, review and implementation of processes and other arrangements within the management system. It also included interviews with a selection of process owners, managers required to implement arrangements developed by process owners, and a number of managers with responsibility for workgroups that manages SL’s LC17 arrangements.
Not applicable; this was not a Safety System inspection.
From the evidence examined, I consider that SL’s arrangements for compliance with LC 17 have improved over the last twelve months. I noted that steps have been taken to manage down the rate of alteration of the management system, and recognised a number of areas of developing good practice; for example some process owners are consulting much more than in the past with the users of their processes to ensure that arrangements are usable and practical. However, the management system at the time of the inspection remains one that is burdensome and difficult for Sellafield staff, resulting in uneven compliance and reducing the efficiency with which hazards of the site are reduced. It is my opinion that SL’s proposed improvement plan should go some considerable way to address this. For these reasons, as a result of this inspection I consider an IIS rating of 4 (Below Standard) is merited against LC17.
My findings were shared with, and accepted by, the licensee at a feedback session at the close of the inspection. A candidate ONR Regulatory Issues has been raised concerning the management system arrangements and their implementation.