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 Programme. In accordance with that Strategy, a Licence Condition compliance inspection of the High Level Waste Plants (HLWP) Operating Unit (OU) was carried out as identified within the planned inspection schedule for the Waste Effluent Disposition Directorate (WEDD).
This planned intervention was undertaken to determine if the HLWP OU is adequately implementing SL's site-wide arrangements for compliance with Licence Conditions 7 (incidents on the site), 12 (duly authorised and other suitably qualified and experienced persons), 26 (control and supervision of operations) and 36 (organisational capability). The HLWP OU was chosen due to the nature of the inventory, the complexity of operations associated with the vitrification of highly active liquor and recently implemented organisational changes.
Licence Condition 7 (LC 7) requires SL to ensure that incidents on the site are notified, recorded, investigated and reported.
Licence Condition 12 (LC 12) requires SL to make and implement adequate arrangements to ensure that only suitably qualified and experienced persons perform duties which may affect the safety of operations on the site. These arrangements shall also provide for the appointment in appropriate cases, of duly authorised persons to control and supervise operations which may affect plant safety.
Licence Condition 26 (LC 26) requires SL to ensure that no operations are carried out which may affect safety except under the control and supervision of suitably qualified and experienced persons appointed for that purpose by SL.
Licence Condition 36 (LC3 6) requires SL to provide and maintain adequate financial and human resources to ensure the safe operation of the licensed site. LC 36 also requires SL to make and implement adequate arrangements to control any change to its organisational structure or resources which may affect safety.
I carried out a two-day, on-site, licence condition compliance inspection of the HLWP OU with support from an ONR Human Factors Specialist Inspector. The main focus of the inspection centred on operations and activities associated within the Waste Vitrification Plant (WVP) since this is the main operational facility within the HLWP OU.
The inspection comprised discussions with Sellafield Ltd staff, observation of operational plant meetings, a plant walk down, and examination of a sample of plant operational records. The inspections were carried out in accordance with the following formal ONR inspection and assessment guidance:
N/A. This was not a Systems Based Inspection (SBI).
From the evidence sampled during this inspection, I consider that Sellafield Ltd has effectively implemented their arrangements for compliance with Licence Condition 7, and that an inspection rating of Green (No Formal Action) is merited.
From the evidence sampled during this inspection, I consider that Sellafield Ltd has shortfalls in their arrangements for compliance with Licence Condition 36, since the justification to substantiate the nuclear baseline could not be provided. I consider that an inspection rating of Amber (Seek improvement) is merited. Although a similar site wide issue is being progressed by ONR, this inspection identified the specific need for the HLWP OU to develop and substantiate a nuclear baseline to ensure that the nuclear safety impact of any future organisational changes can be assessed against an existing and justified nuclear baseline.
From the evidence sampled during this inspection, I consider that Sellafield Ltd has effectively implemented their arrangements for compliance with Licence Condition 12, and consider that an inspection rating of Green (No Formal Action) is merited.
From the evidence sampled during this inspection, I consider that Sellafield Ltd has effectively implemented their arrangement for compliance with Licence Condition 26. Additionally, there was evidence of good practice being applied with the utilisation of a framework of daily group operational meetings that ensured frontline operational and nuclear safety issues were communicated efficiently and effectively up to management and to the wider operational workforce. I consider that an inspection rating of Green (No Formal Action) is merited.
My findings were shared with, and accepted by Sellafield Ltd, as part of routine inspection feedback. In order to provide regulatory oversight of Sellafield Ltd.'s progress against the shortfalls identified I have raised two Regulatory Issues as a result of this inspection that expect Sellafield Ltd: