The Office for Nuclear Regulation (ONR) undertakes all regulatory interactions with Sellafield Limited (SL, the site licensee) in line with 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 between 9-11 December 2015 to examine the adequacy of the site’s arrangements for Examination, Inspection, Maintenance and Testing (EMIT, Licence Condition 28). In particular, the intent of this inspection was to monitor the progress made by SL since 2014 when it committed to an improvement programme (which was accepted by ONR) to close a related regulatory issue. Furthermore, the inspection considered recent shortfalls which had occurred at site in relation to this subject.
The inspection comprised a corporate-level intervention on 9 December to inspect the site-wide arrangements. This was then followed on 10 December by two concurrent interventions at the High Active Liquor Evaporation and Storage (HALES) and Waste Vitrification Plants (WVP) Operating Units, to evaluate and confirm the information presented by SL the previous day. The scope of my work was informed by findings from a separate LC28 inspection carried out in the Decommissioning Directorate the week before.
The HALES and Decommissioning Directorate interventions are reported separately in interventions records ONR-SEL-IR-15-072 and ONR-SEL-IR-15-073.
Not applicable as this was not a Safety System inspection.
From the evidence examined, I consider that SL’s arrangements for compliance with LC28 have improved since 2014. I have considered the different areas where SL committed to make improvements and have looked at evidence, including documents, databases and from interviews, to conclude that important improvements have now been made.
However, I also found that SL’s new LC28 arrangements appear to have been inconsistently implemented across the site. Since the former arrangements no longer represent relevant good practice, I asked SL to provide ONR with a clear roll-out plan and to keep us informed of progress.
The new arrangements for LC28 aim to create synergies between EMIT and SL’s Asset Condition Assessment and Technical Basis of Maintenance processes. The evidence that I collected revealed some inconsistent or missing links between these three areas due to a low maturity of current deployment. I asked SL to pay attention to its roll-out programme and recommended a more collaborative approach between the corporate level and the Operating Units.
I found numerous examples of good practices across HALES and WVP, although the process of implementing the new arrangements across the site is at an early stage. Therefore I have encouraged SL to capture its own good practices and share them across the site to support and reinforce the roll-out of the new arrangements.
Given that the new arrangements appear to represent relevant good practice I consider an IIS rating of 3 (adequate) is merited against LC28.
My findings were shared with, and accepted by, the licensee at a feedback session at the close of the inspection.