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, Decommissioning, Fuel & Waste 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 licensee's compliance with the conditions of its nuclear site licence.
This planned inspection was undertaken to examine the adequacy of SL's site-wide arrangements for compliance with Licence Condition 6 (documents, records, authorities and certificates). This LC was selected as part of our strategy to inspect SL's arrangements for compliance with all relevant licence conditions through a rolling programme over a five year period. There being no previously identified recent matters of particular concern associated with this licence condition, this inspection was assigned a 'routine' priority rating.
LC 6 requires the licensee to make adequate records to demonstrate compliance with any of the conditions attached to a nuclear site licence.
ONR's inspection, which comprised discussions with SL staff and examination of SL documentation, focussed on the following areas:
Not applicable; this was not a safety system inspection.
I consider SL's arrangements for compliance with LC 6 to be good in many areas. For instance, SL has developed the Target Operating Model (TOM) which proposes a centrally-driven and locally-implemented structure with records management resources in both a central team of specialist expertise and within the business areas. It recommends multiple changes across the processes, people & organisation and technology. ONR considers SL's TOM to be a good practice. Furthermore, the all the SL staff encountered were knowledgeable regarding the LC 6 subject area and provided many good quality responses to questions. These findings were, however, offset by the work I believe is still required in this area. SL understands and recognises my concern which relates to issues that should be addressed through SL's Information Asset and Records Management Improvement Programme, currently awaiting business case approval. This will address the long standing concerns regarding the condition, storage arrangements and management of old/legacy records across the site, e.g. inconsistent implementation of the site wide arrangements regarding retention schedules, indexing and onsite storage.
For these reasons, on balance, I awarded an Inspection Rating of Amber (Seek Improvement) against LC 6 for this inspection.
My findings were shared with, and accepted by the licensee as part of normal inspection feedback. I have raised a new Regulatory Issue as a result of this inspection. ONR requested a letter from SL to confirm when the business case for the Information Asset and Records Management Improvement Programme improvement programme has been approved.