The Office for Nuclear Regulation (ONR) undertakes all regulatory interaction with the Sellafield site licensee (Sellafield Limited, SL) against a strategy defined by the ONR Sellafield and Decommissioning, Fuel and Waste (SDFW) Programme. In accordance with that strategy, Licence Condition (LC) compliance inspections on the Plutonium Finishing and Storage Operating Unit (PF&S OU) were carried out, as planned, in May 2016.
The purpose of this inspection was for the ONR to determine the adequacy of implementation of the licensee's formal arrangements for compliance with both LC 24 (operating instructions) and LC 28 (examination, inspection, maintenance and testing). The PF&S OU was selected as the target for this inspection, the hazard controlled by those facilities is significant and the quality of inspection and testing and the adherence to effective written inspections is a key claim made by the licensee within their safety cases for the facilities.
On 18 May 2016, I carried out a one-day, on-site compliance inspection of the PF&S OU, targeting LC 24 and LC 28 performance. The inspection comprised discussions with SL staff, a plant walk-down, and reviews of plant records and other documentation. As part of my preparation for the delivery of this intervention, the following formal ONR guidance documentation was used:
This was not a system based inspection, and therefore no judgement has been made of the adequacy of implementation of any part of the safety case.
During my inspection, I sampled a range of written instructions from a suite that the licensee has identified as supporting safe operations within those facilities for managing plutonium products arising from reprocessing operations on site. In all samples reviewed, the instructions were adequate in content, were clear in presentation, and were related accurately to the relevant part(s) of the facility safety case.
Operational staff were well trained in the content and purpose of the selected instructions, were able to identify the key aspects of each, and, as a result of separate operational demands on the plant at the time of the inspection, demonstrated effective control of the plant whilst using those written instructions to the extent required by the licensee's arrangements.
From those areas sampled, I did not identify any significant shortfalls in the licensee's formal arrangements for compliance with Licence Condition 24 which would prompt an inspection of those arrangements earlier than currently planned.
I inspected the implementation of site arrangements for delivery of safety-based maintenance, inspection and testing. Evidence sampled indicated that the licensee complied fully with all relevant process, and there was specific evidence in support of a robust and self-challenging drive to ensure that no maintenance fell overdue, and indications that the site had already recognised the good performance in PF&S OU and were seeking, where possible, to identify and disseminate related learning.
From those areas sampled, I noted that the arrangements for compliance with Licence Condition 28 carry a greater administrative burden, are complex in nature in their delivery of the Integrated Work Management (IWM) approach at site, are closely linked to formal arrangements for compliance with other key Licence Conditions, and could potentially lead to differing levels of adherence across the site. I have communicated this finding within the ONR Sellafield Compliance, Intelligence and Enforcement (SCIE) sub-programme, to determine if wider site evidence supports this, and thus if further regulatory action is merited.
I consider that the licensee has complied with all legal duties, and that there are only limited opportunities for further ALARP improvements. Therefore, it is my opinion that for against compliance with Licence Condition 24 and Licence Condition 28, IIS ratings of Green (No Formal Action) are merited.
From the evidence sampled during these inspections, I judge that there was sufficient evidence that the licensee's formal arrangements for compliance with Licence Condition 24 and Licence Condition 28 are being implemented adequately.